HAMMEL V. STATE FARM: 3 ZUNIGA DECLARATIONS

HAMMEL V. STATE FARM: 3 ZUNIGA DECLARATIONS: "n. Thus, liability was clear, and that State Farm had
conceded that the treatment (with the exception of the
MRI of March 1995) was reasonable, necessary and
related to each accident (by paying the medical bills).
Nonetheless, State Farm claims that no evaluation was
made and no offer extended until September 1995. Any
reasonable Claims Representative, not bound by the
'low damager' policy would conclude the claim for the
UIM benefits exceeded the policy limits. Further, in
my opinion, the refusal to attempt to settle 'low
damager' cases in a fair, reasonable and prompt manner
was a deliberate company policy arbitrarily implemented
on a region-wide basis without regard to the merits of
individual claims."

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