HAMMEL V. STATE FARM: 3 ZUNIGA DECLARATIONS

HAMMEL V. STATE FARM: 3 ZUNIGA DECLARATIONS: "3. In this capacity, I am aware that there were many other State
Farm claims arising out of the Northridge earthquake like the
Taylors' involving unauthorized signatures by State Farm agents
or agency employees on applications omitting earthquake coverage.
At the time of the Taylor claim, the Company was well aware that
this was a problem. As a matter of practice, the Company would
pay these claims, if it believed that the forgery issue would be
brought to light and proven by the insured. Because of the
forgery issue in the Taylor case, if the case was not dismissed
on summary judgement, it was my impression that the claim was
going to be reconsidered. However, we were waiting to see if we
could save money on the Taylor claim by having summary judgement
granted, and as part of that plan I was instructed not to provide
certain relevant information at my depositions."

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