HAMMEL V. STATE FARM: 3 ZUNIGA DECLARATIONS

HAMMEL V. STATE FARM: 3 ZUNIGA DECLARATIONS: "4. Specifically, my supervisor in the SAC unit, Vanessa Gudelj,
and her supervisor, John Poptanich, put pressure on me to
withhold the existence of documents memorializing certain State
Farm claims handling guidelines from plaintiffs' counsel Bernie
Bernheim at my deposition, which they believed, if revealed,
would defeat summary judgement and ultimately lead to payment of
the Taylors' claim. They pressured me into not revealing the
existence of claims handling documents which established
guidelines under which claims like the Taylors were to be
handled. These included a three ring binder called 'CATHR
Management Information and Memos Manual' used and maintained by
Claim Superintendent Tinga Nicholson who was the Claim
Superintendent that denied the Taylors' claim. It was responsive
to the Taylors' discovery request and we simply chose not to
produce it. Similarly, Ms. Nicholson had prepared a breakdown
of earthquake claims in her unit (the SHU unit - see below) by
category of claim, and one of the categories was 'unauthorized
signatures.' This document showed the percentage of total
earthquake claims which involved unauthorized signatures. This
document, too, was never produced."

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