HAMMEL V. STATE FARM: 3 ZUNIGA DECLARATIONS: "19. I was told of this policy when I was a bodily injury
negotiator by Superintendent Elizabeth Haines in approximately
1993. Haines instructed me to immediately implement this policy
and instructed others to do so as well in my presence. Ms.
Haines instructed me to 'broadcast' this unwillingness to settle
and desire to litigate 'low damager' claims to all plaintiffs
attorneys offices I dealt with. Ms. Haines told me this policy
was being implemented on a regionwide basis."
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