Preview
1 SPENCER Y. KOOK (SBN 205304)
skook@hinshawlaw.com
2 MICHAEL A.S. NEWMAN (SBN 205299)
mnewmanl@hinshawlaw.com
3 KJMIA KARAM! (SBN 334708)
kkarami@hinshawlaw.com
4 HINSHAW & CULBERTSON LLP
350 South GrandAve.,Suite 3600
5 Los Angeles,CA 90071-3476
Telephone: 213-680-2800
6 Facsimile: 213-614-7399
7 LORA D. HEMPHILL(SBN 214654)
KRISTINE N. ULRICH (SBN 310930)
8 HAGER DOWLING
Professional Corporation
9 319 East Carrillo Street
Santa Barbara, CA 93101
10 Telephone: (805) 966-4700
Facsimile: (805) 966-4120
11
Attorneys for Defendant
12 MERCURY CASUALTY COMPANY
13 SUPERIOR COURT OF THE STATE OF CALIFORNIA
14 SAN MATEO COUNTY - UNLIMITED CIVIL JURISDICTION
15 DONNA MARIE MESCH!,an individual, Case No. 16CIV02607
VINCENT MES�HI,an individual,-on behalf
16 of themselves and a class of similarly situated (Assigned to the Hon. Danny Y. Chou)
persons,andROES 1-10,
17 DECLARATION OF SPENCER Y. KOOK
Plaintiffs, IN SUPPORT OF DEFENDANT
18 MERCURY CASUALTY COMPANY'S
vs. OPPOSITION TO PLAINTIFF'S MOTION
19 FOR CLASS CERTIFICATION
MERCURY CASUALTY COMPANY,a (VOLUME 1 OF 3)
20 corporation, andDOES 3 through 10, Hearing Date: July 7, 2022
Hearing Time: 9:00 a.m.
21 Defendants. Department: 22
22 [Concurrently filed with Opposition to Motion
for Class Certification; Objection to
23 Evidence; Declaration of Arthur Wills; and
Declaration of Lola Hogan]
24
Complaint Filed: November 29,2016
25
26
27
28 1
DECLARATION OF SPENCER Y. KOOK
HINSHAW & CULBERTSON u.,, IN SUPPORT OF DEFENDANT MERCURY CASUALTY COMPANY'S
350 South Grand Ave., Suite 3600
Los Angeles, CA 90071-3476 OPPOSITION TO PLAINTIFF'S MOTION FOR CLASS CERTIFICATION
213-680-2800
I 047936\310826972.vl
1 DECLARATION OF SPENCER Y. KOOK
2 I, Spencer Y. Kook, declare and state as follows:
3 1. I am an attorney licensed to practice in all the com1s in the State of California and
4 am a pm1ner at Hinshaw & Culbe11son LLP. I am one of the attorneys with primary responsibility
5 for handling the above captioned matter on behalf of Defendant Mercury Casualty Company
6 ("MCC"). I make this declaration in support of MCC's Opposition to Plaintiff Donna Marie
7 Meschi's ("Plaintiff'') Motion for Class Certification. I have personal knowledge of the facts
8 declared herein and if called upon to testify, I can and will testify competently thereto ..
9 2. Pursuant to order of the Court and agreement of the parties, 200 claim files were
1O produced in this action. Organized in order of the date of loss of those 200 files, attached hereto
11 are true and co1Tect copies of the is the 1st, 66 th , 133 rd and 200 th claim file produced in this action:
12 a. Exhibit 1: Claim file 1 of 200, Mercury Claim No. GY016248;
13 b. Exhibit 2: Claim file 66 of 200, Mercury Claim No. HY015941;
14 C. Exhibit 3: Claim file 133 of 200, Mercury Claim No. OY018166; and
15 d. Exhibit 4: Claim file 200 of 200, Mercury Claim No. JY005295.
16 3. For the Comt's benefit, attached hereto as Exhibit 5 is a demonstrative chm1
17 highlighting certain relevant documents in Exhibits 1 through 4.
18 4. Attached hereto as Exhibit 6 are true and correct copies of excerpts of Plaintiff
19 Donna Meschi's claim file.
20 5. Attached hereto as Exhibit 7 are true and correct copies of excerpts of the February
21 22, 2021 deposition of Plaintiff Donna Meschi.
22
23 I declare under penalty of perjury under the laws of the State of California and the
24 United States of America that the foregoing is true and correct. Executed at Los Angeles,
25 California on May 27, 2022.
26
SPENCER Y. KOOK
27
2
28 DECLARATION OF SPENCER Y. KOOK IN SUPPORT OF DEFENDANT MERCURY CASUALTY COMPANY'S
OPPOSITION TO PLAINTIFF'S MOTION FOR CLASS CERTIFICATION
HINSHAW & CULBERTSON UP
350 South Grand Ave., Suite 3600
Los Angeles, CA 90071•3476
213-680-2800 I 04 7936\310826972. v I
EXHIBIT 1
Mercury Claim Number
GY016248
MERC008181
......
+ .. I
,-----·---· ··1
s4-7933
3970891.. 1
BANK OF AMERICA
Commorcial Disbursement Account
Northbrook, IL
/Jtt\ MERCURY INSURANCE SERVICES 040061 2 2 10
·i:t~
0719
JANUARY 08, 20 1 3
./(t.AIMNO:GY016240-02 POLICY NO: HO 133 36 17 5
DATE OF LOSS: 12/0 3/ 20 1 2
INSURED: PAYMENT FOR: 0306
YOUR FILE:1 18528 TAX 1.D. NO:
33-0'776589 C
EVENT CODE:
PAY THIRTY SIX AND 10/ 100 $ *******36.10
DesoRA (NOT VAUO AFTIJI 8 MO~THS.i~-··
/-/ Sol · GROSS FEDERAL NET ADJ
TO
NATIONAL VENDOR INC J/l,IV o M,d,N AMOUNT TAX AMOUNT
THE
26249 ENTERPRISE CT 9 (01,'3 36.10 36.10 7933
LAKEFOREST,CA 92630-8462
ORDER
OF ¼Ms NOT NEGOTIABLE
SIGNATURE
FILE COPY
MERC008183
CLOSING REPORT
INSURED NAME:
CLAI"l\lNO.: GY016248-02 POLICYNO. HO13336175 U/WBRANCH 13
AGENT: 5168 AGENT NAf¥1E: GROFF & LEVY INS BKRS WEST
DATE OF LOSS: 12/03/2012 DATE REPORTED TO CO.: 12/04/2012 EVENT CODE
RESERVE REVIEW(AT PRINT TIME)
COY. LIMIT GROSS
,;·;.c,:;;,,:,,.,;,Cc,Ci•lcoDE
AMOUNT RESERVE OUTSTANDIN
0l 440,000.00 CSL 4 80.00 .00
03 330,000.00 CSL 6,839.36 .00
REASON FOR CHANGE AT THIS TIME:
NO FURTHER EXPOSURES. NI HAS VERY MINIMAL DEPRECIATION AV AfLABLE. WE
CAN CLOSE THE CLAIM. N
Anthony DiPaolo
SHOULD HA VE BEEN MADE EARLIER? NO IF SO, BY WHOM?
BY: 9580 DATE: 03/28/2013 DATE TO SUBRO: APR O12013
DOES LOSS INVOLVE MOLD? NO CLAIMS
t • \f.J t"r:'': cJ-,1i
c-1 r.1
1119s TRI CrrTF~ RF?. CLAIM corY
i
w.-\r~~:"'\t,·,'--·
,
02 i\·lERCURY ~!ALTY CO~ANY
a :;,2013
Dc,or- . · · · - - - - - - - - - - - - - - - , . _ - - ,. . .- -
•u::.EN Sl!\.rt t._: .,
.. ,
MERC00B184
~!}p~ :M~A~: ltl\
Commercial Disbursement Account
Northbrook, IL
MERCURY INSURANCE GROUP
MERCURY CASUALTY COMPANY
54-9580
27141078 70-2328
-6Tf9-
POLICY NO: HO 13336175 MARCH 20, 20 1 3
CLAIM NO: GY016240-02
INSURED: CLAIMANT: ADDITIONAL STOLEN PROPERTY
PAY ONE HUNDRED FIFTY FOUR AND 61/ 100 $ ****** 154,61
CNOT VAUO AFTE!\ 6 MOl'ITHS.I
A,nthonY DiPao\o
IN PARTIAL SETTLEMENT OF CONTENTS CLAIM!S)
TO
THE MAR 21 20\3 ARISING OUT OF INCIDENT ON 1 2/ 0 312 0 1 2
ORDER
OF
cWMS
-·----N_O_Ts~~~~R11 At!rt.. , .· ,,vi
COVSRAGE PYMT TYPE AMOU.NT ADJUSTER SUBRO
PRODUCER
CODE
5168
PRODUCER NAME
GROFF a LEVY INS BKRs WES
t !!VIS
/
PAYEE TYPE: 1
(',3 F 154,61 9500 EVENT CODE:
CPR:
FILE ,COPY
MERC008185
RESERVE ADJUSTMENT
INSURED NA!\IB:
CLAIMNO.: GY016248-02 POLICYNO. H013336175 U/WBRANCH 13
AGENT: 5168 AGENT NAME: OR OFF & LEVY INS BKRS WEST
DA.TE OF LOSS: 12/03/2012 DATE REPORTED TO CO.: 12/04/2012 EVENT CODE
03 330,000.00 CSL 104.61 0l 440,000.00 CSL 4 80.00 .00
03 330,000.00 CSL 6,839.36 .00
hony DiPao\o
REASON FOR CHANGE AT THIS Tll\IB:
CLAIMS
PAYMENT IN FULL FOR COV C.
SHOULD HA VE BEEN MADE EARLIER? IF SO, BY WHOM?
BY: ~580 DATE: 03/20/2013 DATE TO SlJBRO:
DOES LOSS INVOLVE MOLD'? NO
C-111 11/98 CLAIM COPY
02 MERCURY CASUALTY COMPANY
MERC008186
1
:A;,~;A~E;,~ /Jtl
Commercial Disbursement Account
Northbrook, IL
MERCURY INSURANCE GROUP
MERCURY CASUALTY COMP ANY
27139183 70-2326
-0719
POLICY NO: HO 13336175 MARCH 05, 2013
CLAIMNO: GY016246-02
INSURED: CLAIMANT: WALLS AND BASEBOARD DAMAGES
AnthoOV DiPao\O
PAY FOUR HUNDRED EIGHTY AND 00/ 100 $ ******480.00
~ !N01 VAUO AFTER 8 MO-NT_H_Sl_
MAR 07 20'3
IN PARTIAL SETTLEMENT OF BUILDING CLAIM($)
TO
THE
cl.A'lMS ARISING OUT OF INCIDENT ON 12/03/2012
ORDER
OF
NOT NEGOTIABLE ---~- .
SIGNATURE
PRODUCER PRODUCER NAME
CODE
COVERAGE PYMTTYPE AMOUNT ADJUSTER SUBRO 5168 GROFF & LEVY INS BKRS WEST
01 F 480.00 9580
PAYEE TYPE:
EVENT C~~=: "• &
,
;·:r:.~{-7'1/n
1/1._ .,,,.
1 / i~~.v,
\ , ., .......
W>
CtA\MS
FILE COPY
l
MERC008187
INSURED NAME:
RESER VE ADJUSTMENT
EJ
CLAIM NO.: GY0!6248-02 POLICY NO. HO! 33361 ?S U/W BRANCH 13
AGENT: S 16 8 AGENT NAME: GR01'P & LEVY INS BKRS WEST
DATE OF LOSS: . 12/03/2012 DATE REPORTED TO CO.: 12/04/2012 EVENT CODE
RESERVE REVIEW(AT PRINT TIME)
LIMIT GROSS
AMOUNT RESERVE OUTSTANDIN
01 440,000.00 CSL 330.00 01 440,000.00 CSL 480.00 .00
03 330,000.00 CSL 6,734.75 50.00
REASON FOR CHANGE AT THIS TIME:
PAYMENT IN FULL FOR COVA BUILDING DAMAGES. WALLS AND BASEBOARDS WERE C' AIMS
DAMAGED FROM BREAKIN. MINOR SCRATCHES AND PAINT CIIIPS. Ui
SHOULD HA VE BEEN MADE EARLIER? IF SO, BY WHOM'!
BY: 9S80 DATE: 03/05/2013 DATE TO SUBRO:
DOES LOSS INVOLVE MOLD? NO
C-11-1.
11/98 CLAIM COPY Anthony D1Pao1°
MERCURY CASUALTY COMPANY
MARO 7 20\3
.
CLAIMS
MERC008188
1
::. ~/A:E:,:. ltl
commercial Disbursement Account
Northbrook, IL
MERCURY INSURANCE GROUP
MERCURY CASUALTY COMPANY
[s4.:793Cl
27132456 70-2328
-â—Š719-
POLICY NO: HO 1 3 3 3 6 17 5 JANUARY oe, 20 1 3
CLAIM NO:
INSURED: CLAIMANT: PERSONAL PROPERTY
PAY FIVE THOUSAND SIX HUNDRED FORTY FIVE ANO 14/ I 00 $ ****5,64S.l 4
IN PARTIAL SETTLEMENl OF PER PROP CLAIM(S)
TO
THE
Di:- ARISING OUT OF INCIDENT ON 12/03/2012
t..130/.),.
ORDER
Of
~i
JAN Oo 20 3
'Vil-/ 8
14N O
9 <0
C1"""'t/,
~..
Ol..fl.f,qtv----"-"-N=-OT
iJ
NEGOTIABLE________
SIGNATURE
't·•~
~
PRODUCER
CODE
PRODUCER NAME
COVERAGE PYMT TYPE AMOUNT ..,.,,.,.,_g1 ER
SUBRO 5168 GROFF & LEVY INS BKRS WEST
PA YEE TYPE: 1
03 p 5,645.14 7933 EVENT CODE:
CPR:
FILE COPY
MERC008189
1 7 1 54-7933
::~F A=E~I~ -
commercial Disbursement Account
MERCURY INSURANCE GROUP
MERCURY CASUALTY COMPANY
27132455 70-2328
~
Northbrook, IL
CLAIM NO: GYO 16248-02
POLICY NO: HO t 3336175 JANUARY 08, 2013
INSURED:- CLAIMANT: _...CONTENTS REPLACEMENTS
PAY ONE THOUSAND THIRTY NINE AND 6 I/ 100 $ ****l,039.61
(NOT VALID 'i>n:=:m=-s,-,-MO_,-N-TttS-.)-
IN PARTIAL SETTLEMENT OF PER PROP CLAIM(Sl
NATIONAL VENDOR INC
TO
26249 ENTERPRISE CT 01: ARISING ouT oF 1Nc1DENT oN 1210312012
THE
LAKE FOREST, CA 92630-8412
80
ORDER
OF
/?41-J Bo
JA.N O9 '¼A.N NOT NEGOTIABLE
{01:J ---=.__,SIGNATURE
Ci.AJ"1s PRODUCER PRODUCER NAME
COVERAGE PYMTTYPE ·- ADJUSTER SUBRO
CODE
5168
PAYEE TYPE;
GROFF&. LEVY INS SKAS WEST
5
0,3 p 1,039.6 t 7933 EVENT CODE:
CPR:
FILE COPY
MERC008190
RESER VE ADJUSTMENT
INSURED NAME: /
·CLAIM NO.: GY0l 6248-02 POLICY NO. HO13336175 U/WBRANCH 13
AGENT: 5168 AGENT NAME: GROFF & LEVY INS BKRS WFST
DATE OF LOSS: 12/03/2012 DATE REPORTED TO CO.: 12/04/2012 EVE~'T CODE
RESERVE REVIEW(AT PRINT TIME)
cov. LIMIT GROSS
CODE AMOUNT RESERVE OUTSTANDIN
OJ 330,000.00 CSL 1,634.75 01 440,000.00 CSL 150,00 150.00
03 330,000.00 CSL 6,734.75 50.00
REASON FOR CHANGE AT THIS TIME: JAN O9 20i;J
(
MISSING PROPERTY GREATER THAN ANTICIPATED CLAIMS
SHOULD HA VE BEEN MADE EARLIER? IF SO, BY WHOM? !
f
BY: 7933 DATE: 01/08/2013 DATE TO SUBRO:
DOE9 LOSS CNVOL VE MOLD? NO
C·l 11 11/98 CLAIM COPY
02 . MERCURY CASUALTY COMPANY
MERC008191
MAKE-UP
LOSS DESCRIPTION:
CLAIM NO. ;GY016248-02
THEH FROM INSD HOME,MISSING ITEMS ARE L TODA Y'S DATE : 12/06/2012
APTOP,CLOTHES,HANDBAOS,JEWELRY,HOLIDA Y G ADJUSTER CODE : 79 3 3
IFTS,DAMAGE TO SHEETROCK FROM DOG GATE R POLICY NO. : HO 13336175
IPPED OFF WALL,NO PRIORS
LOSS LOCATION:
01
03
DEB RAH BOLMAN
DOES LOSS INVOLVE MOLD? NO D C O7 2012
78 Mercury Casualty Company .00
MERC008192
DATE & TIME OF LOSS: 12/03/2012 06:05 PM
DATERPT. TOUS; 12/04/2012
REPORTED BY: INSURED
TYPE/CAUSE OF LOSS: 06/01
U/W BRANCH : 13
AGENT CODE: S 168
DATE/RPT. TO AGT.:
EVENT CODE:
C-50P 11/98
-
CLAIM COPY
02 MERCURY CASUALTY COMPANY
MERC008193
10/11/2019 C45 FILE NOTES PCB854 PAGE 1
UNIT 52
C45 NOTES REQUESTED BY BOll VANESSA MALDONADO
CLAIM NO GY016248-02 POLICY NO HO13336175 DOL 12/03/2012
C45 DATE 03/28/2013
C45 Entered By User 9580 ANTHONY DIPAOLO User Type ADJ
09:lSAM CLOSING
9: 14AM I CALLED THE NI . SHE HAS RECEIVE
D THE MOST RECENT PAYMENT THAT WE SENT TO HER. SHE DOESNT HAVE ANY
QUESTIONS OR CONCERNS. I TOLD HER THAT WE WOULD CLOSE THE CLAIM.
POLICY: 810
PRIORS: NONE
LOSS: NI HOME ENTERED M'D ITEMS STOLEN. SUSPECTS CAME THRU DOGGIE DOOR
FINDINGS: NO SUBRO. NO SUSPECTS CAUGHT. NO SALVAGE.
RECOMMENDATIONS: WE CLOSE THE CLAIM. NO NEED TO MONITOR THE CLAIM FOR
REPLACEMENT COST BENEFITS.
SENDING 35 TO LAPD.
C45 DATE 03/22/2013
C45 Entered By User 9580 ANTHONY DIPAOLO User Type ADJ
01:17PM QUALITY ASSURANCE
1: 17PM I CALLED THE NI - A T 818-426-6466. I TOLD HER THAT WE WERE
SENDING HER A CHECK FOR $154.61
MERC008194
10/11/2019 C45 FILE NOTES PCB854 PAGE 2
UNIT 52
C45 NOTES REQUESTED BY BOll VANESSA MALDONADO
CLAIM NO GY016248-02 POLICY NO HO13336175 DOL 12/03/2012
C45 DATE 03/22/2013
C45 Entered By User 9152 LANA INGRAM User Type SUPV
11:45AM FILE REVIEW; DRAFT
PAYMENT FOR SUPPLEMENTAL PROPERTY
APPROVED
C45 DATE 03/08/2013
C45 Entered By User 9580 ANTHONY DIPAOLO User Type ADJ
04:03PM SUPPLEMENTAL PAYMENT
WE ARE GOING TO ISSUE A CHECK TO THE NI FOR $154.61 FOR THE ADDITIONAL
ITEMS THAT THE NI HAD STOLEN. SHE HAD SOME CARRY ON LUGGAGE, A LEATHER
WALLET AND A BEANIE HAT.
RCV: $158.03
DEP: $3.42
ACV: $154. 61
MERC008195
10/11/2019 C45 FILE NOTES l?CB854 PAGE 3
UNIT 52
C45 NOTES REQUESTED BY B0ll VANESSA MALDONADO
CLAIM NO GY016248-02 POLICY NO HO13336175 DOL 12/03/2012
C45 DATE 03/08/2013
C45 Entered By User 9580 ANTHONY DIPAOLO user Type ADJ
02:07PM QUALITY ASSURANCE
2:00PM I CALLED THE NI NO ANSWER, I LEFT A
MESSAGE THAT THE CHECK FOR BUILDING REPAIRS IS ON ITS WAY. WE HAVE
ALSO RECEIVED THE SUPPLEMENTAL INVENTORY LIST THAT THE NI PROVIDED.
WE NEED THE NI TO PROVIDE THE DATES PURCHASED FOR THE THREE ADDITIONAL
ITEMS.
C45 DATE 03/08/2013
C45 Entered By User 9152 LANA INGRAM User Type SUPV
11:38AM FILE REVIEW; DRAFT.
PAYMEN'I' FOR DAMAGES RESULTING FROM THEFT.
APPROVED.
MERC008196
10/11/2019 C45 FILE NOTES PCB854 PAGE 4
UNIT 52
C45 NOTES REQUESTED BY B0ll VANESSA MALDONADO
CLAIM NO GY016248-02 POLICY NO HO13336175 DOL 12/03/2012
C45 DATE 03/04/2013
C45 Entered By User 9580 ANTHONY DIPAOLO User Type ADJ
01:22PM STATUS LETTER BEING SENT T0-
1:00PM I CALLED SHE DID NOT ANSWER. I LEFT A
MESSAGE. I ALSO EMAILED HER. WE ARE REQUESTING THAT SHE PROVIDE THE
SUPPLEMENTAL INVENTORY LIST AND WALLS REPAIR ESTIMATE. NI HAS PROVIDED
PHOTOS OF THE DAMAGED WALLS AND BASEBOARDS. IT APPEARS THAT PAINT IS
THE ONLY REQUIRED TRADE. WE WILL AWAIT THE INFO.
I WILL SEND A STATUS LETTER TO THE NI.
C45 DATE 02/19/2013
C45 Entered By User 9580 ANTHONY DIPAOLO User Type ADJ
08:S0AM CONTACT W/ NI- STATUS DUE 3/8
8: 4SAM I CALLED 1111 SHE TOLD ME THAT SHE IS OBTAINING THE ESTIMATE
AND PHOTOS OF THE DAMAGED WALL. SHE TOLD ME THAT SHE HAD LUGGAGE, HAT,
PURSE AND SOME TOOLS THAT WERE NOT PREVIOUSLY REPORTED. SHE TOLD ME
THAT ALL OF THE ITEMS BELONG TO HER EXCEPT THE BOX FULL OF TOOLS. THOS
E BELONG TO HER BOYFRIEND. HE LIVES AT THE HOME WITH THE NI AS WELL.
MERC008197
10/11/2019 C45 FILE NOTES PCB854 PAGE 5
UNIT 52
C45 NOTES REQUESTED BY B0ll VANESSA MALDONADO
CLAIM NO GY016248-02 POLICY NO HO13336175 DOL 12/03/2012
C45 DATE 02/08/2013
C45 Entered By User 9580 ANTHONY DIPAOLO User Type ADJ
09:0SAM NEW ADJUSTER LETTER
9:07AM I CALLED NI NO ANSWER. 1 LEFT A MESSAGE.
I WILL SEND NEW ADJUSTER LETTER WHICH ALSO REQUESTS COMPLETED
SUPPLEMENTAL INVENTORY LIST, PHOTOS AND ESTIMATE FOR THE REPAIRS TO
THE DAMAGED WALLS.
C45 DATE 01/23/2013
C45 Entered By User 7933 DEBORAH A BOLMAN User Type ADJ
08:45AM DIARY--
OPEN FOR HOLDBACK $3.66, ADDITIONAL INVENTORY, AND 01 REPAIRS ESTIMATE
/PHOTOS
8:36 TC INSD MS CONFIRMED SHE REC'D PAYMENT,SHE
DOES NOT HAVE QUESTIONS,SHE SAID SHE NEEDS INVENTORY FORM FOR ADDITIO
NAL ITEMS,SHE SAID WALL IS STILL DAMAGED FROM DOG GATE RIPPED OFF,TOLD
HER I WILL EMAIL INVENTORY FORM TO HER,ASKED HER TO SEND PHOTO OF DAM
AGES AND SEND ESTIMATE FOR REPAIRS,SHE WILL DO SO
Cl79P TO INSD
RE-DIARY FOR 2/6
NEXT STATUS 2/20
MERC008198
10/11/2019 C45 FILE NOTES PCB854 PAGE 6
UNIT 52
C45 NOTES REQUESTED BY B011 VANESSA MALDONADO
CLAIM NO GY016248·02 POLICY NO 8013336175 DOL 12/03/2012
C45 DATE 01/09/2013
C45 Entered By User 7933 DEBORAH A BOLMAN User Type ADJ
09:53AM DIARY--
INVENTORY IN FROM NATIONAL VENDOR
ORDERED PAYMENTS YESTERDAY
9:49 TC INSD LEFT VM RE:PAYMENTS ON ORDER,GAVE PAYMENT IN
FO,CALL IF ANY QUESTIONS
COMPLETED PAYMENT LETTER AND STATEMENT OF LOSS
RE-DIARY FOR 1/23
NEXT STATUS 2/6
C45 DATE 01/08/2013
C45 Entered By User 7933 DEBORAH A BOLMAN User Type ADJ
04:SSPM ORDERED 03 CHECK TO INSD FOR NON-REPLACED ITEMS
ORDERED 03 CHECK TO NAT VENDOR FOR REPLACEMENTS
ORDERED EXP CHECK TO NAT VENDOR FOR PRICING INVOICE
MERC008199
10/11/2019 C45 FILE NOTES PCB854 PAGE 7
UNIT 52
C45 NOTES REQUESTED BY B011 VANESSA MALDONADO
CLAIM NO GY016248-02 POLICY NO HO13336175 DOL 12/03/2012
C45 DATE 01/07/2013
C45 Entered By User 7933 DEBORAH A BOLMAN User Type ADJ
09:201\.M 9:09 REC'D CALL FROM INSD MS-SHE SAID SHE HEARD FROM JOEL BO
T WANTS TO KNOW WHEN SHE WILL RECEIVE PAYMENT FOR NON-REPLACED ITEMS,L
ET HER KNOW I JUST REC'D THE FINALIZED INVENTORY THIS MORNING,WILL BE
ISSUING PAYMENT AND WILL CALL HER BEFORE PAYMENT GOES OUT,INSD SAID SH
E FOUND A COUPLE ADD ITEMS MISSING,TOLD HER TO ADD TO INVENTORY FORM A
ND MAIL IN TO ME,INSD SAID OK
C45 DATE 12/20/2012
C45 Entered By User 7933 DEBORAH A BOLMAN User Type ADJ
02:06PM INVENTORY SENT TO NATIONAL VENDOR FOR PRICING
MERC008200
10/11/2019 C45 FILE NOTES
Preview
1 SPENCER Y. KOOK (SBN 205304) skook@hinshawlaw.com 2 MICHAEL A.S. NEWMAN (SBN 205299) mnewmanl@hinshawlaw.com 3 KJMIA KARAM! (SBN 334708) kkarami@hinshawlaw.com 4 HINSHAW & CULBERTSON LLP 350 South GrandAve.,Suite 3600 5 Los Angeles,CA 90071-3476 Telephone: 213-680-2800 6 Facsimile: 213-614-7399 7 LORA D. HEMPHILL(SBN 214654) KRISTINE N. ULRICH (SBN 310930) 8 HAGER DOWLING Professional Corporation 9 319 East Carrillo Street Santa Barbara, CA 93101 10 Telephone: (805) 966-4700 Facsimile: (805) 966-4120 11 Attorneys for Defendant 12 MERCURY CASUALTY COMPANY 13 SUPERIOR COURT OF THE STATE OF CALIFORNIA 14 SAN MATEO COUNTY - UNLIMITED CIVIL JURISDICTION 15 DONNA MARIE MESCH!,an individual, Case No. 16CIV02607 VINCENT MES�HI,an individual,-on behalf 16 of themselves and a class of similarly situated (Assigned to the Hon. Danny Y. Chou) persons,andROES 1-10, 17 DECLARATION OF SPENCER Y. KOOK Plaintiffs, IN SUPPORT OF DEFENDANT 18 MERCURY CASUALTY COMPANY'S vs. OPPOSITION TO PLAINTIFF'S MOTION 19 FOR CLASS CERTIFICATION MERCURY CASUALTY COMPANY,a (VOLUME 1 OF 3) 20 corporation, andDOES 3 through 10, Hearing Date: July 7, 2022 Hearing Time: 9:00 a.m. 21 Defendants. Department: 22 22 [Concurrently filed with Opposition to Motion for Class Certification; Objection to 23 Evidence; Declaration of Arthur Wills; and Declaration of Lola Hogan] 24 Complaint Filed: November 29,2016 25 26 27 28 1 DECLARATION OF SPENCER Y. KOOK HINSHAW & CULBERTSON u.,, IN SUPPORT OF DEFENDANT MERCURY CASUALTY COMPANY'S 350 South Grand Ave., Suite 3600 Los Angeles, CA 90071-3476 OPPOSITION TO PLAINTIFF'S MOTION FOR CLASS CERTIFICATION 213-680-2800 I 047936\310826972.vl 1 DECLARATION OF SPENCER Y. KOOK 2 I, Spencer Y. Kook, declare and state as follows: 3 1. I am an attorney licensed to practice in all the com1s in the State of California and 4 am a pm1ner at Hinshaw & Culbe11son LLP. I am one of the attorneys with primary responsibility 5 for handling the above captioned matter on behalf of Defendant Mercury Casualty Company 6 ("MCC"). I make this declaration in support of MCC's Opposition to Plaintiff Donna Marie 7 Meschi's ("Plaintiff'') Motion for Class Certification. I have personal knowledge of the facts 8 declared herein and if called upon to testify, I can and will testify competently thereto .. 9 2. Pursuant to order of the Court and agreement of the parties, 200 claim files were 1O produced in this action. Organized in order of the date of loss of those 200 files, attached hereto 11 are true and co1Tect copies of the is the 1st, 66 th , 133 rd and 200 th claim file produced in this action: 12 a. Exhibit 1: Claim file 1 of 200, Mercury Claim No. GY016248; 13 b. Exhibit 2: Claim file 66 of 200, Mercury Claim No. HY015941; 14 C. Exhibit 3: Claim file 133 of 200, Mercury Claim No. OY018166; and 15 d. Exhibit 4: Claim file 200 of 200, Mercury Claim No. JY005295. 16 3. For the Comt's benefit, attached hereto as Exhibit 5 is a demonstrative chm1 17 highlighting certain relevant documents in Exhibits 1 through 4. 18 4. Attached hereto as Exhibit 6 are true and correct copies of excerpts of Plaintiff 19 Donna Meschi's claim file. 20 5. Attached hereto as Exhibit 7 are true and correct copies of excerpts of the February 21 22, 2021 deposition of Plaintiff Donna Meschi. 22 23 I declare under penalty of perjury under the laws of the State of California and the 24 United States of America that the foregoing is true and correct. Executed at Los Angeles, 25 California on May 27, 2022. 26 SPENCER Y. KOOK 27 2 28 DECLARATION OF SPENCER Y. KOOK IN SUPPORT OF DEFENDANT MERCURY CASUALTY COMPANY'S OPPOSITION TO PLAINTIFF'S MOTION FOR CLASS CERTIFICATION HINSHAW & CULBERTSON UP 350 South Grand Ave., Suite 3600 Los Angeles, CA 90071•3476 213-680-2800 I 04 7936\310826972. v I EXHIBIT 1 Mercury Claim Number GY016248 MERC008181 ...... + .. I ,-----·---· ··1 s4-7933 3970891.. 1 BANK OF AMERICA Commorcial Disbursement Account Northbrook, IL /Jtt\ MERCURY INSURANCE SERVICES 040061 2 2 10 ·i:t~ 0719 JANUARY 08, 20 1 3 ./(t.AIMNO:GY016240-02 POLICY NO: HO 133 36 17 5 DATE OF LOSS: 12/0 3/ 20 1 2 INSURED: PAYMENT FOR: 0306 YOUR FILE:1 18528 TAX 1.D. NO: 33-0'776589 C EVENT CODE: PAY THIRTY SIX AND 10/ 100 $ *******36.10 DesoRA (NOT VAUO AFTIJI 8 MO~THS.i~-·· /-/ Sol · GROSS FEDERAL NET ADJ TO NATIONAL VENDOR INC J/l,IV o M,d,N AMOUNT TAX AMOUNT THE 26249 ENTERPRISE CT 9 (01,'3 36.10 36.10 7933 LAKEFOREST,CA 92630-8462 ORDER OF ¼Ms NOT NEGOTIABLE SIGNATURE FILE COPY MERC008183 CLOSING REPORT INSURED NAME: CLAI"l\lNO.: GY016248-02 POLICYNO. HO13336175 U/WBRANCH 13 AGENT: 5168 AGENT NAf¥1E: GROFF & LEVY INS BKRS WEST DATE OF LOSS: 12/03/2012 DATE REPORTED TO CO.: 12/04/2012 EVENT CODE RESERVE REVIEW(AT PRINT TIME) COY. LIMIT GROSS ,;·;.c,:;;,,:,,.,;,Cc,Ci•lcoDE AMOUNT RESERVE OUTSTANDIN 0l 440,000.00 CSL 4 80.00 .00 03 330,000.00 CSL 6,839.36 .00 REASON FOR CHANGE AT THIS TIME: NO FURTHER EXPOSURES. NI HAS VERY MINIMAL DEPRECIATION AV AfLABLE. WE CAN CLOSE THE CLAIM. N Anthony DiPaolo SHOULD HA VE BEEN MADE EARLIER? NO IF SO, BY WHOM? BY: 9580 DATE: 03/28/2013 DATE TO SUBRO: APR O12013 DOES LOSS INVOLVE MOLD? NO CLAIMS t • \f.J t"r:'': cJ-,1i c-1 r.1 1119s TRI CrrTF~ RF?. CLAIM corY i w.-\r~~:"'\t,·,'--· , 02 i\·lERCURY ~!ALTY CO~ANY a :;,2013 Dc,or- . · · · - - - - - - - - - - - - - - - , . _ - - ,. . .- - •u::.EN Sl!\.rt t._: ., .. , MERC00B184 ~!}p~ :M~A~: ltl\ Commercial Disbursement Account Northbrook, IL MERCURY INSURANCE GROUP MERCURY CASUALTY COMPANY 54-9580 27141078 70-2328 -6Tf9- POLICY NO: HO 13336175 MARCH 20, 20 1 3 CLAIM NO: GY016240-02 INSURED: CLAIMANT: ADDITIONAL STOLEN PROPERTY PAY ONE HUNDRED FIFTY FOUR AND 61/ 100 $ ****** 154,61 CNOT VAUO AFTE!\ 6 MOl'ITHS.I A,nthonY DiPao\o IN PARTIAL SETTLEMENT OF CONTENTS CLAIM!S) TO THE MAR 21 20\3 ARISING OUT OF INCIDENT ON 1 2/ 0 312 0 1 2 ORDER OF cWMS -·----N_O_Ts~~~~R11 At!rt.. , .· ,,vi COVSRAGE PYMT TYPE AMOU.NT ADJUSTER SUBRO PRODUCER CODE 5168 PRODUCER NAME GROFF a LEVY INS BKRs WES t !!VIS / PAYEE TYPE: 1 (',3 F 154,61 9500 EVENT CODE: CPR: FILE ,COPY MERC008185 RESERVE ADJUSTMENT INSURED NA!\IB: CLAIMNO.: GY016248-02 POLICYNO. H013336175 U/WBRANCH 13 AGENT: 5168 AGENT NAME: OR OFF & LEVY INS BKRS WEST DA.TE OF LOSS: 12/03/2012 DATE REPORTED TO CO.: 12/04/2012 EVENT CODE 03 330,000.00 CSL 104.61 0l 440,000.00 CSL 4 80.00 .00 03 330,000.00 CSL 6,839.36 .00 hony DiPao\o REASON FOR CHANGE AT THIS Tll\IB: CLAIMS PAYMENT IN FULL FOR COV C. SHOULD HA VE BEEN MADE EARLIER? IF SO, BY WHOM? BY: ~580 DATE: 03/20/2013 DATE TO SlJBRO: DOES LOSS INVOLVE MOLD'? NO C-111 11/98 CLAIM COPY 02 MERCURY CASUALTY COMPANY MERC008186 1 :A;,~;A~E;,~ /Jtl Commercial Disbursement Account Northbrook, IL MERCURY INSURANCE GROUP MERCURY CASUALTY COMP ANY 27139183 70-2326 -0719 POLICY NO: HO 13336175 MARCH 05, 2013 CLAIMNO: GY016246-02 INSURED: CLAIMANT: WALLS AND BASEBOARD DAMAGES AnthoOV DiPao\O PAY FOUR HUNDRED EIGHTY AND 00/ 100 $ ******480.00 ~ !N01 VAUO AFTER 8 MO-NT_H_Sl_ MAR 07 20'3 IN PARTIAL SETTLEMENT OF BUILDING CLAIM($) TO THE cl.A'lMS ARISING OUT OF INCIDENT ON 12/03/2012 ORDER OF NOT NEGOTIABLE ---~- . SIGNATURE PRODUCER PRODUCER NAME CODE COVERAGE PYMTTYPE AMOUNT ADJUSTER SUBRO 5168 GROFF & LEVY INS BKRS WEST 01 F 480.00 9580 PAYEE TYPE: EVENT C~~=: "• & , ;·:r:.~{-7'1/n 1/1._ .,,,. 1 / i~~.v, \ , ., ....... W> CtA\MS FILE COPY l MERC008187 INSURED NAME: RESER VE ADJUSTMENT EJ CLAIM NO.: GY0!6248-02 POLICY NO. HO! 33361 ?S U/W BRANCH 13 AGENT: S 16 8 AGENT NAME: GR01'P & LEVY INS BKRS WEST DATE OF LOSS: . 12/03/2012 DATE REPORTED TO CO.: 12/04/2012 EVENT CODE RESERVE REVIEW(AT PRINT TIME) LIMIT GROSS AMOUNT RESERVE OUTSTANDIN 01 440,000.00 CSL 330.00 01 440,000.00 CSL 480.00 .00 03 330,000.00 CSL 6,734.75 50.00 REASON FOR CHANGE AT THIS TIME: PAYMENT IN FULL FOR COVA BUILDING DAMAGES. WALLS AND BASEBOARDS WERE C' AIMS DAMAGED FROM BREAKIN. MINOR SCRATCHES AND PAINT CIIIPS. Ui SHOULD HA VE BEEN MADE EARLIER? IF SO, BY WHOM'! BY: 9S80 DATE: 03/05/2013 DATE TO SUBRO: DOES LOSS INVOLVE MOLD? NO C-11-1. 11/98 CLAIM COPY Anthony D1Pao1° MERCURY CASUALTY COMPANY MARO 7 20\3 . CLAIMS MERC008188 1 ::. ~/A:E:,:. ltl commercial Disbursement Account Northbrook, IL MERCURY INSURANCE GROUP MERCURY CASUALTY COMPANY [s4.:793Cl 27132456 70-2328 -◊719- POLICY NO: HO 1 3 3 3 6 17 5 JANUARY oe, 20 1 3 CLAIM NO: INSURED: CLAIMANT: PERSONAL PROPERTY PAY FIVE THOUSAND SIX HUNDRED FORTY FIVE ANO 14/ I 00 $ ****5,64S.l 4 IN PARTIAL SETTLEMENl OF PER PROP CLAIM(S) TO THE Di:- ARISING OUT OF INCIDENT ON 12/03/2012 t..130/.),. ORDER Of ~i JAN Oo 20 3 'Vil-/ 8 14N O 9 <0 C1"""'t/, ~.. Ol..fl.f,qtv----"-"-N=-OT iJ NEGOTIABLE________ SIGNATURE 't·•~ ~ PRODUCER CODE PRODUCER NAME COVERAGE PYMT TYPE AMOUNT ..,.,,.,.,_g1 ER SUBRO 5168 GROFF & LEVY INS BKRS WEST PA YEE TYPE: 1 03 p 5,645.14 7933 EVENT CODE: CPR: FILE COPY MERC008189 1 7 1 54-7933 ::~F A=E~I~ - commercial Disbursement Account MERCURY INSURANCE GROUP MERCURY CASUALTY COMPANY 27132455 70-2328 ~ Northbrook, IL CLAIM NO: GYO 16248-02 POLICY NO: HO t 3336175 JANUARY 08, 2013 INSURED:- CLAIMANT: _...CONTENTS REPLACEMENTS PAY ONE THOUSAND THIRTY NINE AND 6 I/ 100 $ ****l,039.61 (NOT VALID 'i>n:=:m=-s,-,-MO_,-N-TttS-.)- IN PARTIAL SETTLEMENT OF PER PROP CLAIM(Sl NATIONAL VENDOR INC TO 26249 ENTERPRISE CT 01: ARISING ouT oF 1Nc1DENT oN 1210312012 THE LAKE FOREST, CA 92630-8412 80 ORDER OF /?41-J Bo JA.N O9 '¼A.N NOT NEGOTIABLE {01:J ---=.__,SIGNATURE Ci.AJ"1s PRODUCER PRODUCER NAME COVERAGE PYMTTYPE ·- ADJUSTER SUBRO CODE 5168 PAYEE TYPE; GROFF&. LEVY INS SKAS WEST 5 0,3 p 1,039.6 t 7933 EVENT CODE: CPR: FILE COPY MERC008190 RESER VE ADJUSTMENT INSURED NAME: / ·CLAIM NO.: GY0l 6248-02 POLICY NO. HO13336175 U/WBRANCH 13 AGENT: 5168 AGENT NAME: GROFF & LEVY INS BKRS WFST DATE OF LOSS: 12/03/2012 DATE REPORTED TO CO.: 12/04/2012 EVE~'T CODE RESERVE REVIEW(AT PRINT TIME) cov. LIMIT GROSS CODE AMOUNT RESERVE OUTSTANDIN OJ 330,000.00 CSL 1,634.75 01 440,000.00 CSL 150,00 150.00 03 330,000.00 CSL 6,734.75 50.00 REASON FOR CHANGE AT THIS TIME: JAN O9 20i;J ( MISSING PROPERTY GREATER THAN ANTICIPATED CLAIMS SHOULD HA VE BEEN MADE EARLIER? IF SO, BY WHOM? ! f BY: 7933 DATE: 01/08/2013 DATE TO SUBRO: DOE9 LOSS CNVOL VE MOLD? NO C·l 11 11/98 CLAIM COPY 02 . MERCURY CASUALTY COMPANY MERC008191 MAKE-UP LOSS DESCRIPTION: CLAIM NO. ;GY016248-02 THEH FROM INSD HOME,MISSING ITEMS ARE L TODA Y'S DATE : 12/06/2012 APTOP,CLOTHES,HANDBAOS,JEWELRY,HOLIDA Y G ADJUSTER CODE : 79 3 3 IFTS,DAMAGE TO SHEETROCK FROM DOG GATE R POLICY NO. : HO 13336175 IPPED OFF WALL,NO PRIORS LOSS LOCATION: 01 03 DEB RAH BOLMAN DOES LOSS INVOLVE MOLD? NO D C O7 2012 78 Mercury Casualty Company .00 MERC008192 DATE & TIME OF LOSS: 12/03/2012 06:05 PM DATERPT. TOUS; 12/04/2012 REPORTED BY: INSURED TYPE/CAUSE OF LOSS: 06/01 U/W BRANCH : 13 AGENT CODE: S 168 DATE/RPT. TO AGT.: EVENT CODE: C-50P 11/98 - CLAIM COPY 02 MERCURY CASUALTY COMPANY MERC008193 10/11/2019 C45 FILE NOTES PCB854 PAGE 1 UNIT 52 C45 NOTES REQUESTED BY BOll VANESSA MALDONADO CLAIM NO GY016248-02 POLICY NO HO13336175 DOL 12/03/2012 C45 DATE 03/28/2013 C45 Entered By User 9580 ANTHONY DIPAOLO User Type ADJ 09:lSAM CLOSING 9: 14AM I CALLED THE NI . SHE HAS RECEIVE D THE MOST RECENT PAYMENT THAT WE SENT TO HER. SHE DOESNT HAVE ANY QUESTIONS OR CONCERNS. I TOLD HER THAT WE WOULD CLOSE THE CLAIM. POLICY: 810 PRIORS: NONE LOSS: NI HOME ENTERED M'D ITEMS STOLEN. SUSPECTS CAME THRU DOGGIE DOOR FINDINGS: NO SUBRO. NO SUSPECTS CAUGHT. NO SALVAGE. RECOMMENDATIONS: WE CLOSE THE CLAIM. NO NEED TO MONITOR THE CLAIM FOR REPLACEMENT COST BENEFITS. SENDING 35 TO LAPD. C45 DATE 03/22/2013 C45 Entered By User 9580 ANTHONY DIPAOLO User Type ADJ 01:17PM QUALITY ASSURANCE 1: 17PM I CALLED THE NI - A T 818-426-6466. I TOLD HER THAT WE WERE SENDING HER A CHECK FOR $154.61 MERC008194 10/11/2019 C45 FILE NOTES PCB854 PAGE 2 UNIT 52 C45 NOTES REQUESTED BY BOll VANESSA MALDONADO CLAIM NO GY016248-02 POLICY NO HO13336175 DOL 12/03/2012 C45 DATE 03/22/2013 C45 Entered By User 9152 LANA INGRAM User Type SUPV 11:45AM FILE REVIEW; DRAFT PAYMENT FOR SUPPLEMENTAL PROPERTY APPROVED C45 DATE 03/08/2013 C45 Entered By User 9580 ANTHONY DIPAOLO User Type ADJ 04:03PM SUPPLEMENTAL PAYMENT WE ARE GOING TO ISSUE A CHECK TO THE NI FOR $154.61 FOR THE ADDITIONAL ITEMS THAT THE NI HAD STOLEN. SHE HAD SOME CARRY ON LUGGAGE, A LEATHER WALLET AND A BEANIE HAT. RCV: $158.03 DEP: $3.42 ACV: $154. 61 MERC008195 10/11/2019 C45 FILE NOTES l?CB854 PAGE 3 UNIT 52 C45 NOTES REQUESTED BY B0ll VANESSA MALDONADO CLAIM NO GY016248-02 POLICY NO HO13336175 DOL 12/03/2012 C45 DATE 03/08/2013 C45 Entered By User 9580 ANTHONY DIPAOLO user Type ADJ 02:07PM QUALITY ASSURANCE 2:00PM I CALLED THE NI NO ANSWER, I LEFT A MESSAGE THAT THE CHECK FOR BUILDING REPAIRS IS ON ITS WAY. WE HAVE ALSO RECEIVED THE SUPPLEMENTAL INVENTORY LIST THAT THE NI PROVIDED. WE NEED THE NI TO PROVIDE THE DATES PURCHASED FOR THE THREE ADDITIONAL ITEMS. C45 DATE 03/08/2013 C45 Entered By User 9152 LANA INGRAM User Type SUPV 11:38AM FILE REVIEW; DRAFT. PAYMEN'I' FOR DAMAGES RESULTING FROM THEFT. APPROVED. MERC008196 10/11/2019 C45 FILE NOTES PCB854 PAGE 4 UNIT 52 C45 NOTES REQUESTED BY B0ll VANESSA MALDONADO CLAIM NO GY016248-02 POLICY NO HO13336175 DOL 12/03/2012 C45 DATE 03/04/2013 C45 Entered By User 9580 ANTHONY DIPAOLO User Type ADJ 01:22PM STATUS LETTER BEING SENT T0- 1:00PM I CALLED SHE DID NOT ANSWER. I LEFT A MESSAGE. I ALSO EMAILED HER. WE ARE REQUESTING THAT SHE PROVIDE THE SUPPLEMENTAL INVENTORY LIST AND WALLS REPAIR ESTIMATE. NI HAS PROVIDED PHOTOS OF THE DAMAGED WALLS AND BASEBOARDS. IT APPEARS THAT PAINT IS THE ONLY REQUIRED TRADE. WE WILL AWAIT THE INFO. I WILL SEND A STATUS LETTER TO THE NI. C45 DATE 02/19/2013 C45 Entered By User 9580 ANTHONY DIPAOLO User Type ADJ 08:S0AM CONTACT W/ NI- STATUS DUE 3/8 8: 4SAM I CALLED 1111 SHE TOLD ME THAT SHE IS OBTAINING THE ESTIMATE AND PHOTOS OF THE DAMAGED WALL. SHE TOLD ME THAT SHE HAD LUGGAGE, HAT, PURSE AND SOME TOOLS THAT WERE NOT PREVIOUSLY REPORTED. SHE TOLD ME THAT ALL OF THE ITEMS BELONG TO HER EXCEPT THE BOX FULL OF TOOLS. THOS E BELONG TO HER BOYFRIEND. HE LIVES AT THE HOME WITH THE NI AS WELL. MERC008197 10/11/2019 C45 FILE NOTES PCB854 PAGE 5 UNIT 52 C45 NOTES REQUESTED BY B0ll VANESSA MALDONADO CLAIM NO GY016248-02 POLICY NO HO13336175 DOL 12/03/2012 C45 DATE 02/08/2013 C45 Entered By User 9580 ANTHONY DIPAOLO User Type ADJ 09:0SAM NEW ADJUSTER LETTER 9:07AM I CALLED NI NO ANSWER. 1 LEFT A MESSAGE. I WILL SEND NEW ADJUSTER LETTER WHICH ALSO REQUESTS COMPLETED SUPPLEMENTAL INVENTORY LIST, PHOTOS AND ESTIMATE FOR THE REPAIRS TO THE DAMAGED WALLS. C45 DATE 01/23/2013 C45 Entered By User 7933 DEBORAH A BOLMAN User Type ADJ 08:45AM DIARY-- OPEN FOR HOLDBACK $3.66, ADDITIONAL INVENTORY, AND 01 REPAIRS ESTIMATE /PHOTOS 8:36 TC INSD MS CONFIRMED SHE REC'D PAYMENT,SHE DOES NOT HAVE QUESTIONS,SHE SAID SHE NEEDS INVENTORY FORM FOR ADDITIO NAL ITEMS,SHE SAID WALL IS STILL DAMAGED FROM DOG GATE RIPPED OFF,TOLD HER I WILL EMAIL INVENTORY FORM TO HER,ASKED HER TO SEND PHOTO OF DAM AGES AND SEND ESTIMATE FOR REPAIRS,SHE WILL DO SO Cl79P TO INSD RE-DIARY FOR 2/6 NEXT STATUS 2/20 MERC008198 10/11/2019 C45 FILE NOTES PCB854 PAGE 6 UNIT 52 C45 NOTES REQUESTED BY B011 VANESSA MALDONADO CLAIM NO GY016248·02 POLICY NO 8013336175 DOL 12/03/2012 C45 DATE 01/09/2013 C45 Entered By User 7933 DEBORAH A BOLMAN User Type ADJ 09:53AM DIARY-- INVENTORY IN FROM NATIONAL VENDOR ORDERED PAYMENTS YESTERDAY 9:49 TC INSD LEFT VM RE:PAYMENTS ON ORDER,GAVE PAYMENT IN FO,CALL IF ANY QUESTIONS COMPLETED PAYMENT LETTER AND STATEMENT OF LOSS RE-DIARY FOR 1/23 NEXT STATUS 2/6 C45 DATE 01/08/2013 C45 Entered By User 7933 DEBORAH A BOLMAN User Type ADJ 04:SSPM ORDERED 03 CHECK TO INSD FOR NON-REPLACED ITEMS ORDERED 03 CHECK TO NAT VENDOR FOR REPLACEMENTS ORDERED EXP CHECK TO NAT VENDOR FOR PRICING INVOICE MERC008199 10/11/2019 C45 FILE NOTES PCB854 PAGE 7 UNIT 52 C45 NOTES REQUESTED BY B011 VANESSA MALDONADO CLAIM NO GY016248-02 POLICY NO HO13336175 DOL 12/03/2012 C45 DATE 01/07/2013 C45 Entered By User 7933 DEBORAH A BOLMAN User Type ADJ 09:201\.M 9:09 REC'D CALL FROM INSD MS-SHE SAID SHE HEARD FROM JOEL BO T WANTS TO KNOW WHEN SHE WILL RECEIVE PAYMENT FOR NON-REPLACED ITEMS,L ET HER KNOW I JUST REC'D THE FINALIZED INVENTORY THIS MORNING,WILL BE ISSUING PAYMENT AND WILL CALL HER BEFORE PAYMENT GOES OUT,INSD SAID SH E FOUND A COUPLE ADD ITEMS MISSING,TOLD HER TO ADD TO INVENTORY FORM A ND MAIL IN TO ME,INSD SAID OK C45 DATE 12/20/2012 C45 Entered By User 7933 DEBORAH A BOLMAN User Type ADJ 02:06PM INVENTORY SENT TO NATIONAL VENDOR FOR PRICING MERC008200 10/11/2019 C45 FILE NOTES