HAMMEL V. STATE FARM: 3 ZUNIGA DECLARATIONS

HAMMEL V. STATE FARM: 3 ZUNIGA DECLARATIONS: "HIDING OTHER DOCUMENTS

15. Further, in connection with my retention as an expert
witness in this case, I have reviewed the deposition transcript
of Chris Arnold and have determined that said witness
misrepresented, either intentionally or inadvertently, the
existence of certain documents. Specifically, I am aware that
State Farm generates and maintains lists of law firms that were
generally used for outside counsel. Mr. Arnold denied the
existence of such a list. There are two such lists, an accepted
group of attorneys for first party claims and an accepted group
of attorneys for third party claims. Claims representatives have
to be certified in writing that claims representatives have been
certified as reviewing the Uniform Claims Practices Act and
regulations promulgated thereunder. State Farm keeps these
records and Mr. Arnold as a superintendent, knows this."

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