The Progress of this case will be followed from a


in chronological order with links to appropriate documents.

Top of Memorandum on the
Racketeering Nature of State Farm's Misconduct
for which this is an exhibit.

The List of Exhibits

                        Exhibit 4

   Bird, Samantha F. / GRLY/38- HPDESK Print.
   Message Dated: 04/06/90 at 1504.
   Subject: PURGNG OLD FILES Contents: 2
   Sender: Samantha F. Bird/ GRYL/38
   Cc: Samantha F. Bird/ GRYL/38
   Part 1.
   To: Clark Davis /GRYL/38
   Marcia Daybell/GRYL/38
   Felix Jensen/GRYL/38
   Susan E. More/GRYL/38
   Jerry L. Stevenson/GRYL/04
   Paul L. West/GRYL/38
   Carol J. Young/GRYL/38
   CC: Samantha F. Bird/GRYL/38
   Robert Dean Noxon/GRYL/38
   Part 2.
   Yesterday in the staff meeting, we talked about the need to purge our
   desks of all old memo's, notes and procedural guides. With the
   increase of bad faith suits bieng filed against State Farm, it is
   important that you get rid of all your old stuff: Know you have
   lurking around in your drawers and filing cabinets.
   Please get rid of any old memo's, claim school notes, old seminar or
   claim conference notes, and any old procedure guides you may have.
   They are trying to avoid having to come up with old records when the
   "request for production of documents" comes in and they request "all
   training manuals, memos, procedural guides, etc. that are in the
   possession of your claims reps and management". Apparantly, they had a
   request like this in Texas and each person had to surrender all their
   old junk. I guess corporate is not even going to keep old CPG guides,
   old claim manuals, etc. We will only have what is currently in effect.
   That way if they subpoena our claim manual for U claims for 1987, for
   example, we will say we dont have it. This should be easier than
   trying to produce it or having to defend it.
   So, look through all your old stuff and dump it. You wont ever miss
   Also we discussed that every employee has the right to look at his or
   her personnel file without recrimination. There should be nothing in
   your personnel file that you dont already have a copy of. But if you
   feel the need to see something in your file, it is open to you.


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