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Racketeering Nature of State Farm's Misconduct
for which this is an exhibit.

The List of Exhibits

                          Exhibit 3

   April 10, 1997
   MEMO TO: Tom L'Hote
   FROM: Bill Hardt
   SUBJECT: CAPA Galvanization
   Tom, I basically agree with everything that Jack Gillis sets out in
   his CAPA Update on Galvanization. He does, however, slant the emphasis
   toward his interest, but in essence everything is accurate.
   The only thing I wish to point out is that regardless of the
   effectiveness of priers versus galvanization, the point is that if an
   OE [Original Equipment] part is galvanized, and we use an aftermarket
   part that is primed, there is a difference. We may well say it is
   like, kind and quality, but the bottom line is that it is not the
   Another point Jack makes is in regard to some object penetrating the
   primer on galvanization and exposing the underlying metal to
   corrosion. I think it is relatively common knowledge that it is much
   easier to dislodge the primer than it is the galvanization, thus, the
   protection is not the same in that situation. A good example might be
   when its necessary for a shop to drill a part. If they drill the
   galvanizing, the underlying metal is exposed to corrosion just as it
   would be if there was primer which was drilled through. In that case,
   the body shop should be spraying a primer coating on the exposed metal
   to provide the corrosion resistance. In fact, what I am saying is that
   the collision repair industry uses the primers in reapplying the
   corrosion resistance when they repair cars, so that it is obviously


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Created: February 4, 2000
Last Updated: May 28, 2000