The Progress of this case will be followed from a

CASE DIARY

in chronological order with links to appropriate documents.



	   
	ABSTRACT:

			DECLARATION OF AMY GIROD ZUNIGA

	I, Amy Girod Zuniga, declare as follows.

	1.  I am an adult over the age of 18 and am not a party to this
	action.  I have personal knowledge of all of the following, and
	if called as a witness I could and would testify competently to
	the truth thereof.

	2.  I am a former employee of State Farm Fire and Casualty Co.
	and State Farm Mutual Automobile Insurance Co.  (collectively,
	"State Farm" or "the Company").  I was employed there from 1988
	through mid-1996, and in fact separated during the pendency of
	the Taylor litigation.  Since August of 1994, I worked first in
	the Automobile Company's so-called "SAC" unit ("Suits Against the
	Company" unit) and then in the Fire Company's SAC unit.  Later
	these units were renamed, "Litigation Units." My most recent job
	title before separation from the Company was Claims Specialist.
	My responsibilities included evaluating bad faith suits brought
	against the Company by insureds, responding to discovery and
	monitoring litigation.  I did so in connection with the Taylor
	litigation.

	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.

	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.

	5.  The Taylors' claim was denied by personnel working in the
	so-called "Special Handling Unit." In addition to the claims
	handling documents mentioned above, we never produced to Mr.
	Bernheim a document memorializing a SHU meeting at which the
	subject of unauthorized signatures on applications omitting
	earthquake insurance was discussed.  This document has a heading
	as follows:

	"Problem areas
	   - Telephone apps [applications]
	   - EQ [earthquake] has to be in person.
	Und. [Underwriting] was supposed to catch 'not signed'
	   - in some cases the agent or staff signed it."

	6.  In the SAC unit, we knew that Rod Taylor's signature on the
	application was clearly not his signature.

	I declare under penalty of perjury under the laws of the State of
	California that the foregoing is true and correct.  Executed this
	19th day of September, 1996 at Ojai, California.

	Amy Girod Zuniga




	Bernie Bernheim (SB #144319)
	Kick & Bernheim
	201 N. Figueroa Street, Suite 700
	Los Angeles, California 90012
	(213)975-1588

	Lawyers for Plaintiffs
	Roderick Taylor and Krista Taylor

                 SUPERIOR COURT FOR THE STATE OF CALIFORNIA

                     IN AND FOR THE COUNTY OF LOS ANGELES

RODERICK TAYLOR, an individual; and   )       CASE NO.:BC 119992
KRISTA TAYLOR,  an individual         )
          Plaintiffs,                 )         (Case assigned to the Honorable
                                      )         Charles McCoy for all purposes)
                                      )
vs.                                   )         DECLARATION OF AMY GIROD
                                      )         ZUNIGA IN SUPPORT OF
                                      )         PLAINTIFFS' MOTIONS FOR
                                      )         RECONSIDERATION AND
STATE FARM FIRE AND CASUALTY          )         MOTION FOR NEW TRIAL
COMPANY, et al.,                      )
         Defendants.                  )         DATE:  November 5, 1996
                                      )         TIME:  8:30 AM
______________________________________)         DEPT.: 24
-                                     )         DISCOVER CUTOFF:  Vacated
AND RELATED CROSS-ACTIONS             )         MOTION CUTOFF:  Nov.24,1996
______________________________________)         TRIAL DATE:  Dec. 9, 1996
-

                    DECLARATION OF AMY GIROD ZUNIGA

	I Amy Girod Zuniga, declare as follows:

	1.  I am an adult over the age of 18 and am not a party to this
	action.  I have personal knowledge of all of the following, and
	if called as a witness I could and would testify competently to
	the truth thereof.

	2.  I am a former employee of State Farm Fire and Casualty Co.
	and State Farm Mutual Automobile Insurance Co.  (collectively,
	"State Farm" or the "Company").  I was employed there from 1988
	through mid-1996, and in fact separated during the pendency of
	the Taylor litigation.  Since August of 1994, I worked first in
	the Automobile Company's so-called "SAC" unit ("Suits Against the
	Company" unit) and then in the Fire Company's SAC unit.  Later
	these units were renamed, "Litigation Units." My most recent job
	title before separation from the Company was Claims Specialist.
	My responsibilities included evaluating bad faith suits brought
	against the Company by insureds, responding to discovery and
	monitoring litigation.  I did so in connection with the Taylor
	litigation.

	3.  Mr.  John Poptanich, Divisional Claim Superintendent, was
	head of my Litigation Unit in part of 1995 and 1996.  Michael Coy
	Kendall, Divisional Claim Superintendent, was his predecessor.
	There was also a Costa Mesa Litigation Unit.  Its personnel
	included Ralph Carlino, Dana Dillabough, Diane Andrikos, Dave








	Capirillo.  There was also a General Claim Litigation Unit headed
	by Jim Stark.  Its members included Mary Ann Ridgeway, who
	observed me in the first session of my deposition and Mary
	Bowman.

	4.  I have reviewed many of the papers and declarations which
	State Farm submitted in support of its summary judgement motion
	and opposition to plaintiffs' motion for leave to amend.

	5.  While I was working on the Taylor case at the State Farm SAC
	unit, Mr.  Richard Churik, the operator of the Automatic
	Insertion Machine ("AIM") and others at State Farm made
	statements to me which are inconsistent with much of what is
	contained in State Farm's papers and declarations.

	6.  I made a number of inspections of the AIM system with its
	operator Richard Churik, with underwriting superintendent Charles
	G.  "Glenn" Hook, with attorney G.  Arthur Meneses of the law
	firm of Berger, Kahn, et al, and with a consultant named Don
	Winslow.  Mr.  Winslow was making a film about the AIM for use in
	the Taylor case, and was advising us in how we could present the
	AIM to a jury in such a way as to maximize its strengths and
	gloss over or hide its weaknesses.

	7.  Mr.  Churik verbally explained the workings of the automatic
	insertion machine to Mr.  Meneses, Mr.  Winslow and me.  Mr.
	Churik explained that after the machine has stopped due to a
	failure to pick up a stuffer, the operator can override and
	restart even if the operator has not manually corrected the
	problem.  Mr.  Winslow and I discussed the fact that if an
	operator became frustrated with the repeated failure of one of
	the bins to function correctly, he could simply ignore the
	problem and allow incorrectly stuffed envelopes to be mailed out.
	Mr.  Winslow and I agreed that in reality the machine was only as
	good as the operators working it, and that this was a problem we
	would have to address in making the film.  I worked on "cleaning
	up" the mail room crew for the film.

	8.  Mr.  Winslow and I observed the machine for an extended
	period of time on several occasions.  We observed the machine
	stopping numerous times due to some malfunction.  In fact, I
	would go so far as to say that I observed this occurring
	regularly.

	9.  Near the machine, Mr.  Winslow and I observed a square
	receptacle resembling a square bucket in which were a bunch of
	crumpled up mailer-type documents.  They were covered in
	splotches of red ink, for some reason.  I asked Mr.  Winslow if
	this bucket of crumpled up insurance documents concerned him at
	al, and he replied, in substance, "We won't take a picture of
	that."

	10.  Posted on one of the walls is a large sign, stating in
	substance: "DO NOT LEAVE PREMIUM NOTICES ON THE FLOOR." I
	understood this to be evidence that someone had been leaving



                                    - 2 -






	important insurance documents lying around on the floor of the
	room housing the AIM system.  I discussed this matter with Mr.
	Winslow because it concerned me.  He responded that we take only
	close-up shots of the machine operating so that the sign would
	not appear in the film.

	11.  I am myself a State Farm homeowners policyholder.  I told
	Mr.  Meneses that I, personally, had received not once, but on
	two separate occasions, renewal certificates belonging to another
	policyholder which had somehow been inadvertently stuffed into
	envelopes with my own renewal certificates.  This caused me
	concern.  Mr.  Meneses did not respond.

	12.  A State Farm unit called "Administrative Services" has a
	manual for operation of the AIM called a "service text, ." which
	contains a section or sections pertaining to the AIM system,
	dated July 1993.  It was responsive to the Taylors' request for
	production.  Mr.  Meneses and I discussed whether to produce it
	to plaintiffs' counsel Bernie Bernheim.  We decided not to
	identify it or produce it.  Mr.  Churik had informed us that he
	had not been in compliance with procedures in the "service text"
	pertaining to maintenance of the "control sheets." The "control
	sheets" were daily documentation pertaining to the particular
	runs made by the AIM system.  If there was more than one control
	sheet for a particular day, that would show that a "re-run" had
	to be performed, indicating that there was a mistake in the
	original run.  Mr.  Churik told me that the failure to maintain
	the control sheets as set forth in the service text was a
	mistake.  I was concerned that if this mistake got out, it would
	undermine the credibility of the AIM system.  Mr.  Meneses voiced
	the same concern to me.  We decided not to identify or produce
	the service text, and instead to keep its existence from
	plaintiffs' counsel.

	13.  I noted that in his declaration, State Farm underwriting
	superintendent Charles "Glenn" Hook relied on State Farm PDQ
	computer screen printouts for his testimony that offers and
	notifications were mailed to the mailing address on the policy.
	These PDQ screens require special training to read and interpret.
	Based on my training in interpreting these PDQ screens, and on my
	review of the exhibits filed in support and opposition the motion
	for summary judgement, it is clear to me that the PDQ screen
	printouts for the early 1990s on which Mr.  Hook relied were
	materially inaccurate.

	14.  In my review of the exhibits, I saw that none of the
	declarations pages for the Stoneridge policy contained a warning
	that there was no earthquake coverage, other than one created
	during litigation by Mr.  Hook for the 1993-1994 policy period.
	This is contradictory to statements Mr.  Hook made to me prior to
	my separation from the Company.  Mr.  Hook told me that a
	homeowners declaration page for a policy where there is no
	earthquake coverage is supposed to have a warning under the
	Company's business practices.





                                    - 3 -







	15.  I was repeatedly told by my supervisor Claim Superintendent
	Vanessa Gudelj never to use the word "forgery" in connection with
	the forgeries of the signatures of State Farm insureds by State
	Farm agents and agency employees.  She told me to always use the
	term "unauthorized signature" instead, whenever discussing this
	subject.  I and some of the other SAC unit personnel referred to
	the word "forgery" as the "F-word."

	16.  John Bishop is one of the Company's senior executives at the
	corporate headquarters in Bloomington, Illinois.  His title is
	Senior Claim Consultant.  During 1996, he regularly participated
	in telephone conference calls pertaining to the Taylors.  Sandra
	Hobbs is a long-time employee of State Farm agent Harry Gelpar.
	During Ms.  Hobbs' deposition, I had a very lengthy cellular
	phone conference call with Mr.  Bishop.  Also participating in
	the call was my supervisor Vanessa Gudelj, and her supervisor
	John Poptanich.  No outside attorneys participated in this call,
	and in fact Mr.  Meneses later expressed to me the sentiment that
	he was concerned that he had not been invited.

	17.  During this call, Mr.  Bishop stated that State Farm
	witnesses should not admit that forgeries happen, unless and
	until they are compelled to do so by Court order.  Mr.  Bishop
	asked us whether we think that the Company will ultimately have
	to admit that this happens.  Mr.  Bishop went on to state that we
	have to decide how to tell our story should the Company be
	compelled to admit that it has knowledge of the "unauthorized
	signatures." He said we should try to make this practice look
	like a "service."

	18.  There is an insurance company called American Home which
	provides errors and omissions coverage for State Farm's agents.
	There are certain circumstances in which a law suit naming a
	State Farm agent is tendered to American Home for a defense and
	indemnification.  At one point, I questioned whether the Taylors'
	suit naming Mr.  Gelpar should be tendered to American Home.  I
	was told that there was no point to doing so, because American
	Home would not accept the tender in State Farm agent forgery
	cases.  I was told that the reason for this was that American
	Home took the position that State Farm had ample notice of
	conduct of this type by its agents, and that State Farm had taken
	no meaningful steps to correct the problem.  Therefore, American
	Home's position was that State Farm had ratified and authorized
	the agents' conduct, so that State Farm was responsible for
	claims arising out of this type of conduct.  American Home took
	the position that State Farm, not American Home, should therefore
	be responsible for paying these kinds of claims.

	19.  I was aware of the existence of a number of documents
	pertaining to the Company's practices and procedures regarding
	signatures and the taking of applications by agents which were
	never produced to plaintiffs in the Taylor case.  There is a
	series of documents called "communiques" which are sent by the
	Company to agents.  These are produced by the Education and




                                    - 4 -







	Training Department.  There was an entire "communique binder"
	which was maintained by Ms.  Marci Chairenza of the Education and
	Training Department.  Before Ms.  Chairenza, it was maintained by
	Ms.  Lenore Hatzenbiler, who now works in public affairs.  This
	binder contains an index.  Among the communiques which may be
	relevant to the Taylor case but which have never been produced
	are "Signatures on New Applications - Personal & Commercial,"
	92-45-F, d.  August 25, 1992; "Earthquake Offer Update," 91-14-F,
	d.  March 19, 1991; and "Earthquake Offer," 92-60-F, d.  December
	17, 1992.  I have heard that there are other policy and procedure
	documents sent to agents by the Company called "green sheets."

	20.  In discovery, the Taylors requested that the Company produce
	its claims manuals.  The Company calls its claims manuals,
	"Operations Guides." The Operations Guides produced to the
	Taylors were not a complete set of the Operations Guides, nor
	even a complete set of the Operations Guides pertaining to the
	handling of earthquake claims.  Rather, plaintiffs were given a
	carefully created packet from which material had been removed.
	The material removed included the index.  The tactic behind
	producing this "created packet" of Operations Guides was to give
	plaintiffs something containing no damaging information, but
	which was voluminous enough to distract their attorneys.

	21.  David Tannenbaum is a Company employee who works in a unit
	formerly called "the Discovery Unit," whose task is to locate and
	produce documents and other information in response to discovery
	requests.  This unit is located in Bloomington and is headed by
	Ms.  Chris Lynch.

	22.  I was informed by David Tannenbaum that identical, screened
	packets of Operations Guides were to be produced in all
	earthquake cases in response to discovery requests which asked in
	substance for "all policies and procedures regarding earthquake
	claims handling," regardless of the specifics of the particular
	facts of the case, and that is what I did.  In fact, I do not
	recall any earthquake case in which I produced anything in the
	way of policies and procedures other than the created packet
	described above.  Not producing the index, for example, would
	greatly limit the ability of plaintiffs to request other relevant
	operations guides.

	23.  Prior to my deposition, I was specifically instructed by my
	supervisor, Vanessa Gudelj, not under any circumstances to "give
	up" the name of David Tannenbaum to plaintiffs' counsel Bernie
	Bernheim, nor to reveal Mr.  Tannenbaum's role.  I received the
	same instructions with regard to Mr.  Tannenbaum's colleague, Mr.
	Tim Crouthamel, who also worked at the corporate headquarters in
	Bloomington, Illinois.

	24.  I produced lengthy memoranda analyzing the discovery
	requests made by the Taylors through their counsel, Bernie
	Bernheim.  I forwarded these memoranda to the Discovery Unit.





                                    - 5 -







	25.  In discovery responses, the Taylors asked State Farm to
	identify the dates on which AIM system runs had to be repeated
	due to errors.  State Farm informed the Taylors that there is no
	such documentation kept.  This is not entirely accurate, in that
	there are records kept of the postage which is placed on the
	envelopes.  An unusually high amount of postage for a particular
	date would indicate that an AIM run had to be repeated.  I
	discussed this with Mr.  G.  Arthur Meneses of Berger, Kahn, et
	al, and he dismissed it.

	26.  The Taylors brought a Colonial Life discovery motion, which
	was never heard due to the granting of State Farm's summary
	judgement motion and the denial of plaintiffs' motion for leave
	to file a third amended complaint.  This motion sought among
	other documents, all Special Handling Unit claims files arising
	out of the Northridge earthquake, and all claims files handled by
	Tinga Nicholson, Dale Henderson, and Toni Hotzel arising out of
	the Northridge earthquake.

	27.  There were about 2000 SHU files.  They were inventoried on a
	PC by claims superintendent Tinga Nicholson.  My understanding is
	that these were primarily kept at the Lindero office.  Some may
	have been sent to "the pit," which is a claims file storage
	facility in Newbury Park.  In Shekhter v.  State Farm, a Los
	Angeles superior court case, I participated in a team which had
	to review hundreds of claims files for production pursuant to a
	Colonial Life motion and court order.

	28.  The Company has a computer program on its system called
	"Search Express" for locating documents.  Search terms can be
	inputted to generate lists of responsive documents, in a fashion
	similar to the Internet.

	29.  At the second session of my deposition, the subject of my
	separation from State Farm came up.  I took a break with G.
	Arthur Meneses of Berger, Kahn, et al., whom the Company had
	appointed to represent me in the second session of my deposition.
	During the break, I told Mr.  Meneses that I felt he had a
	conflict of interest in representing both me personally and my
	former employer at this deposition.  I told him that I intended
	to fire him as a result.  He called my former supervisor, Vanessa
	Gudelj, and had a lengthy telephone conversation with her.  After
	his conversation, he returned with a written script which Ms.
	Gudelj had prepared for me to use in answering deposition
	questions.  Mr.  Meneses was apologetic in communicating this to
	me.  I did not feel it was appropriate for me to respond to
	deposition questions with "answers" memorized from a written
	script.  Moreover, what was in the script was not the truth.  We
	returned to the deposition room, and I had resolved to testify to
	the truth.  When the deposition resumed, Mr.  Bernheim asked if I
	felt uncomfortable discussing the subject of my separation from
	State Farm.  I said that I did, and he moved to another topic.






                                    - 6 -







	30.  Giving me this written script to follow at my deposition was
	typical of the practices and procedures I observed at the Company
	in connection with the preparation of Company witnesses for
	deposition.  As part of my duties at the SAC unit, I participated
	in the preparation of many witnesses for deposition.

	31.  The Company routinely retained professional witness
	consultants to prepare State Farm employees for giving testimony
	at deposition and at trial.  Over the years, these consultants
	have Mr.  Steve Herzberg and Mr.  Don Winslow.  Typically, such
	consultants would spend many hours training witnesses on how to
	give up as little information as possible at deposition.
	Witnesses were trained to answer questions as literally as
	possible.  An example that was commonly used in training
	witnesses was the question, "Where is your car parked right now?"
	During preparation, the witness would initially offer an answer
	like, "In the parking lot downstairs." The witness would then be
	told, in substance, that this was an incorrect answer because the
	witness was assuming that the car had not been stolen, or towed
	away, or otherwise moved since the time the witness had last seen
	his or her car.  The witness would be told that the only correct
	answer to this question was, therefore, "I do not know." Other
	tactics that were provided to the witness for use in deposition
	included not looking directly at the examiner, since eye contact
	would tend to facilitate meaningful communication and the giving
	of information.  Witnesses were taught not to answer a question
	with a "yes" or "no," to minimize the likelihood of giving a
	truly responsive answer.  A yes or no does not give "wiggle room"
	to change the answer at a later time.  Witnesses were taught to
	pretend not to understand the initial deposition admonition, to
	throw off the insureds' attorney.  The entire point of this
	training was to make it as difficult as possible for the
	insureds' attorney to learn any meaningful information about the
	Company, its practices or the insureds' claim.

	32.  At trial, the Company's witness tactics are different.
	Consultants like Mr.  Herzberg and Mr.  Winslow trained the
	Company's witnesses to act completely differently for the jury
	trial than at deposition.  Witnesses were trained to appear
	helpful and polite, and to drop the evasive tactics used to keep
	information from being disclosed at deposition.

	33.  Don Winslow prepared underwriting superintendent Charles G.
	"Glenn" Hook for his deposition taken by plaintiffs' counsel
	Bernie Bernheim in the Taylor case.  I referred to Mr.  Winslow
	as a "spin doctor," because he was talented at helping us mold a
	witness' story on a particular topic so that it would become the
	story we wanted to tell.  In Mr.  Hooks' case, the story we
	wanted to tell was about the supposed infallibility of the
	Company's system for complying with statutory earthquake offers
	and notifications.  As was sometimes the case in the Company's
	witness preparation sessions which I participated in, many people
	attended the Hook session and added their input into how the
	witness was going to tell the story.  The Hook deposition prep
	was attended at various times by, among others: Costa Mesa SAC



                                    - 7 -







	unit claims superintendent Diane Andrikos, Melody Caplan, AIM
	operator Richard Churik, John Poptanich, myself, and spin doctor
	Don Winslow.

	I declare under penalty of perjury under the laws of the State of
	California that the foregoing is true and correct.  Executed this
	25th day of September, 1996 at Ojai, California.

	Amy Girod Zuniga

















































                                    - 8 -





	Bernie Bernheim (SB #144319)
	Kick & Bernheim
	201 N. Figueroa Street, Suite 700
	Los Angeles, California 90012
	(213)975-1588

	Lawyers for Plaintiffs
	Roderick Taylor and Krista Taylor



                  SUPERIOR COURT FOR THE STATE OF CALIFORNIA

                     IN AND FOR THE COUNTY OF LOS ANGELES

RODERICK TAYLOR, an individual; and   )        CASE NO.:BC 119992
KRISTA TAYLOR,  an individual         )
          Plaintiffs,                 )         (Case assigned to the Honorable
                                      )         Charles McCoy for all purposes)
                                      )
                 vs.                  )         DECLARATION OF AMY GIROD
                                      )         ZUNIGA IN SUPPORT OF
                                      )         PLAINTIFFS' MOTION FOR
                                      )         RECONSIDERATION
STATE FARM FIRE AND CASUALTY          )
COMPANY, et al.,                      )
         Defendants.                  )         DATE:  , 1996
                                      )         TIME:  8:30 AM
______________________________________)         DEPT.: 24
-                                     )
AND RELATED CROSS-ACTIONS             )         TRIAL DATE:  Dec. 9, 1996
______________________________________)
-

                         DECLARATION OF AMY ZUNIGA

	I, Amy Girod Zuniga, declare and state as follows:

	1.  I am over the age of 18 and not a party to this action.  I
	make this declaration in opposition to the Motion for Summary
	Judgment and could and would competently testify to the facts set
	forth herein if called as a witness.

	2.  I am a former employee of State Farm Fire & Casualty Company
	and State Farm Mutual Automobile Insurance Company (collectively,
	"State Farm" or "the Company").  I was employed there from 1988
	through mid-1996.  Since August of 1994, I worked first in the
	automobile company's so-called "SAC" unit.  These units were
	later renamed "litigation units." My responsibilities included
	evaluating bad faith suits brought against the company by
	insureds, responding to discovery, monitoring litigation,
	interviewing witnesses, assisting in the preparation of witnesses
	for deposition, reviewing pleadings, responding to inquiries as
	to how State Farm's policies were to interpreted as well as
	responding to general questions which were raised regarding State
	Farm's response to a particular situation.  Prior to my
	assignment to the SAC unit, I worked as a claims specialist and
	claims representative in automobile related claims.










	3.  As a result of my work with State Farm I became familiar with
	the procedures and practices of State Farm, the company policies
	and approaches of State Farm to particular types of litigation,
	including litigation arising out of automobile accidents which
	involved bodily injury.  I also became familiar with the methods
	of training and materials provided to claims representatives by
	State Farm.  Finally, as a result of reviewing literally
	thousands of State Farm files and of my knowledge of the
	procedures at State Farm, I have knowledge and understanding of
	what documents and materials are to be included in State Farm
	files.

			 THE CLAIMS FILE AND ATTORNEY'S FILE

	4. I have reviewed the documents bates stamped LSSF 0001 through
	   0909.  The first page of said documents is a cover letter from an
	   attorney representing State Farm (Syna N.  Dennis at Atkins &
	   Evans) which states that the enclosure constitutes the "claims
	   file" in connection with both the accident of November, 1993 and
	   the accident of February, 1995.

	5. Her statement was false.  The materials provided were
	   incomplete.  Portions of what was expected to be included in the
	   claims file were not produced and in the documents produced there
	   was reference to documents in the claim file which were not
	   included.  No list of any items that were privileged was
	   provided.  (I am advised that State Farm contends nothing was
	   withheld.) The response to the Request for Production seeking the
	   claim files specified that the claim file would be produced.
	   This response was false.

	6. I have also reviewed the deposition of Chris Arnold, claims
	   superintendent, which was taken in this matter.  That transcript
	   reveals that Mr.  Arnold acknowledged that the entire claims file
	   had not been provided and that counsel for State Farm agreed to
	   obtain and provide the remainder of the claims file.

	7. I have been provided with documents that have been bates
	   stamped LSSFS 0001-392 which were purportedly produced as the
	   remainder of the claim file on or about October 28, 1996.

	8. I have also been provided with a copy of the "attorney's
	   file" produced by State Farm bates stamped KF 1-517.

	9. Having reviewed the documents bates stamed LSSF, those bates
	   stamped LSSFS and those bates stamped KF 1-517, based upon my
	   knowledge of the practices and procedures of State Farm the
	   following items were not produced and have never been identified
	   by State Farm as being part of the claims file or attorney's
	   file.  These items were clearly called for by the first Request
	   for Production of Documents submitted by the plaintiff in this
	   matter.






                                   - 2 -







	      a.  A key letter (1/31/95) to Mr. Rowell (LS1050) from the Claims
		  Representative was not in the claims file, nor
		  in the attorney's file (although a draft from Bartholmew's
		  office was included).

	      b.  Even assuming these claims were classified as a "low
		  impact"/"low damager" claims, there should have been
		  evaluations in the file. There were none.

	      c.  The "coverage card" on the first loss which was included
	          was not created until July, 1995 (it should have been
	          created as soon as the file was transferred to the bodily
	          unit in January of 1995.) The progress reports show that
	          Mr. Arnold repeatedly checked the box stating "reserves
	          adequate" which he could not have done unless a coverage
	          card was opened earlier. This earlier card has not been
	          produced.

	      d.  The following records are not included in either the
	          claims file or the attorneys file.

		  i.   The Allstate Insurance Company records, produced
	               on May 30, 1995 (194 pages).

		  ii.  The Leon H. Brooks records, produced on
	               October 18, 1995 (108 pages).

		  iii. The records of Bi-Coastal Payroll Services,
	               produced on September 28, 1995.

		  iv.  The records of Dr. Howard Aaron Aronow produced
	               on October 4, 1995 (20 pages).

		  v.   The records of Transamerica Insurance Group produced
	               on October 25, 1995 (505 pages).

	10.  These documents should have been included in one or both
	files.  The documentation regarding claims handling does not
	appear complete, and entries in the attorney's bills reflecting
	conversations with claim's people are not reflected in the claims
	file.

	11.  Additionally, after agreeing to a Stipulation and Order Re:
	Confidentiality which was provided to me by plaintiff's counsel,
	I reviewed the documents which have been bates stamped SFCM
	0001-0094.  According to the Stipulation and Protective Order
	these are all portions of the claims manual and/or claims
	handling procedures documents which are responsive to the Request
	for Production of Documents submitted by the plaintiff, Request
	No.  1, Item No.  2.  State Farm did not identify any portion
	that was not produced (as required by the stipulation).

	12.  Based on my own personal knowledge, State Farm's response to
	the Request for Production is false and materially incomplete.




                                   - 3 -







	13.  State Farm maintains extremely detailed "Claims Procedures
	Guides" comprised of thousands of pages dealing specifically with
	individual coverages under automobile policies and claims
	handling procedures with respect to each claim.  State Farm also
	maintains a smaller document called the "Auto Claims Manual"
	which, in most cases, is more general in approach.

	14.  Although both these documents were requested, State Farm has
	only produced two portions of the "Auto Claims Manual" and has
	neither produced nor identified other portions of the "Auto
	Claims Manual" which are applicable to Mrs.  Stoliar's claims.
	In particular, the uninsured/underinsured motorists section of
	the Auto Claims Manual has not been produced.  Additionally, the
	miscellaneous section of the Auto Claims Manual referred to in
	the bodily injury section dealing with "first call" settlements
	(which was apparently attempted with respect to the February,
	1995 accident by Ann Spratt) was not produced.  State Farm has
	not produced nor identified any portion of the Claims Procedures
	Guide which is applicable to Mrs.  Stoliar's claims.

			   HIDING OTHER DOCUMENTS

	 15.  Further, in connection with my retention as an expert
	witness in this case, I have reviewed the deposition transcript
	of Chris Arnold and have determined that said witness
	misrepresented, either intentionally or inadvertently, the
	existence of certain documents.  Specifically, I am aware that
	State Farm generates and maintains lists of law firms that were
	generally used for outside counsel.  Mr.  Arnold denied the
	existence of such a list.  There are two such lists, an accepted
	group of attorneys for first party claims and an accepted group
	of attorneys for third party claims.  Claims representatives have
	to be certified in writing that claims representatives have been
	certified as reviewing the Uniform Claims Practices Act and
	regulations promulgated thereunder.  State Farm keeps these
	records and Mr.  Arnold as a superintendent, knows this.

	16.  Further, Additionally, Mr.  Arnold did not identify any
	Suits Against Company State Farm representatives as being present
	when he was prepared for his testimony.  According to well
	established policy, a representative of the SAC unit must be
	present when he is prepared for testimony.

	17.  Based upon my review of the portions of the claims files I
	have reviewed (LSSF 1-909, LSSFS 1-302, and the depositions of
	certain of the Claims Representatives, I have concluded as
	follows:

	      a.  Per a State Farm policy adopted in approximately 1993 in my
		  region, no offer was to be made on the  November, 1993
		  accident because it was apparently classified as a
		  "minor-impact" or "low damager" claim.

	      b.  This categorization was unreasonable since State Farm
	          knew that there was almost $3,000.00 in property damage
	          from this accident.  The continued use of the curb side


                                   - 4 -







	          eye ball estimate as the damage to the Stoliar's was
	          also unreasonable because State Farm knew the Stoliar
	          vehicle had sustained in excess of $1,000.00 in
	          property damage.

	      c.  Even the use of the actual repair and amount of
	          property damage to the insured's vehicle alone as a
	          basis for determining whether a case was a "minor
	          impact" or "low damager" was unreasonable since in
	          my experience as a claims representative the amount
	          of total damage sustained and repairs performed on
	          both vehicles is a much more reliable indicator of
	          the severity of the collision.

			     THE COMPANY "LOW DAMAGER" POLICY

	18.  By company policy "minor impact"/"low damager" claims were
	not to be settled.  Instead they were to be "fully litigated" and
	every effort was to be made to make it financially unfeasible for
	the insured to obtain any benefits regardless of whether
	liability was clear or not.  The company policy was to "fully
	litigate" such claims by:

		  i.   retaining "outside" counsel rather than attempt
	               to resolve the claims;

		  ii.  instructing outside counsel commence formal discovery;

		  iii. retaining biomechanical experts and accident
		       reconstructionists on "low damager" cases;

		  iv.  instructing outside counsel subpoena records
	               instead of using authorizations to obtain medical
	               and employment records;

		  v.   taking depositions of the claimant/insured, even
	               after the insured had voluntarily given a recorded
	               statement; and

		  vi.  forcing the insured/claimant to undergo so-called IME's
		       performed by doctors the company was confident would give
		       reports unfavorable to the claimant/insured.

	19.  I was told of this policy when I was a bodily injury
	negotiator by Superintendent Elizabeth Haines in approximately
	1993.  Haines instructed me to immediately implement this policy
	and instructed others to do so as well in my presence.  Ms.
	Haines instructed me to "broadcast" this unwillingness to settle
	and desire to litigate "low damager" claims to all plaintiffs
	attorneys offices I dealt with.  Ms.  Haines told me this policy
	was being implemented on a regionwide basis.

	20.  During this conversation and others Ms.  Haines and Angelo
	Mazza (Divisional Claim Manager, now two levels above Mr.  Arnold
	in the chain of command) communicated the "low damager" policy to
	me and others in my presence.


                                   - 5 -







	21.  The stated goal and purpose of the "low damager" policy was
	to make it unprofitable, too expensive and costly, for
	plaintiff's attorneys to handle "low damager" cases, even those
	in which liability was clear.  As explained to me, the results of
	the policy were intended to be a short-term increase in legal
	fees for the company but a significant long term decrease in
	benefits payments once the plaintiffs bar became aware that
	handling "low damager" cases would be too costly and
	unprofitable.  From both personal experience and from what I have
	been told at State Farm, this policy was extremely effective.
	When I left the comply in August of 1996 the "low damager" policy
	was still in effect.

			 THE HANDLING OF THE STOLIAR CLAIMS

	22.  I have been provided and have reviewed the following
	materials at the request of Mr.  Rowell:

	   a. I have been provided with copies of the portions of the
	      claims file transmitted to Mr.  Rowell on August 30, 1996, bates
	      stamped LSSF 1-909.  I have also been provided with copies of
	      portions of the claims file transmitted to Mr.  Rowell with a
	      letter of enclosed dated October 23, 1996 from Robert P.  Andris
	      of the law firm of Ropers, Majeski, Kahn and Bently, bates
	      stamped LSSFS1-382.

	   b. I have reviewed the records of American Data Med copied from
	      Transamerica Insurance Group at the request of State Farm
	      comprising 505 pages which bear a declaration indicating that the
	      custodian of records produced said records on October 25, 1995 to
	      American Data Med.

	   c. I have reviewed the records of Howard Aaron Aronow obtained
	      by American Data Med on or about October 4, 1995 according to the
	      American Data Med declaration submitted therewith.

	   d. I have reviewed the records of Dr. Lee Sadja obtained by
	      American Data Med pursuant to declaration on October 4, 1995.

	   e. I have reviewed the records of Charles Wexler obtained from his
	      office by American Data Med pursuant to subpena per declaration of
	      June 2, 1995.

	   f. I have reviewed the records of Bi-Coastal Payroll Services
	      obtained from the custodian of records at Bi-Coastal Payroll
	      Services pursuant to a declaration on September 28, 1995.

	   g. I have reviewed the records of Dr.  Leon Brooks obtained from
	      his offices by American Data Med pursuant to declaration on
	      October 18, 1995.

	   h. I have reviewed the records of Allstate Insurance Company
	      obtained by American Data Med from the Woodland Hills office
	      pursuant to declaration on May 30, 1995.




                                   - 6 -







	   i. I have reviewed the records of Physical Medicine and
	      Rehabilitation from Gerald B.  Rosenberg, M.D.  obtained by
	      American Data Med on or about October 23, 1996.

	   j. I have reviewed the deposition of Richard A.  Lonie
	      taken in this matter on September 20, 1996.

	   k. I have reviewed the deposition of Seyed Roghani taken on
	      September 17, 1996 in this matter.

	   l. I have reviewed the deposition of Cathy D.  Wright taken
	      in this matter on October 2, 1996.

	   m. I have reviewed the deposition of Christopher O'Neal
	      Arnold taken in this matter on October 18, 1996, volume 1.

	   n. I have reviewed volume 1 of the deposition of Traci M.
	      Bell taken in this matter on September 20, 1996 and volume 2
	      taken in this matter on October 2, 1996.

	   o. I have reviewed the deposition of Richard Scott Smith
	      taken in this matter on September 17, 1996.

	   p. I have reviewed the deposition of John D.  Rowell and the
	      exhibits attached thereto taken on August 15, 1996 (volume 1).

	   q. I have reviewed the deposition of John D.  Rowell taken
	      September 6, 1996 (volume 2).

	   r. I have reviewed the deposition of Robert Tessier, Esq.
	      taken in this matter on October 14, 1996.

	   s. I have reviewed the deposition of Ann Gilmartin Spratt
	      taken in this matter on September 18, 1996.

	   t. I have reviewed the State Farm attorneys filed together
	      with the privilege log indicating three pages of documents are
	      considered to be privileged and have been withheld and bates
	      stamped KF 1-517 (KF 399-397 were identified as privileged and
	      not produced and I have not reviewed those documents).

	   u. I have reviewed the deposition of Dr.  Lee Sadja, M.D.
	      taken in this matter on and October 15, 1996.

	   v. I have reviewed the deposition of Jerome Lewis, Ph.D.
	      taken in this matter on October 8, 1996.

	   w. I have reviewed the deposition of D.  Martin Bennet,
	      M.D.  taken in this matter on October 7, 1996.

	   x. I have reviewed the deposition of Dr.  Louis Vazquez,
	      M.D.  taken in this matter on October 10, 1996.

	   y. I have reviewed the deposition of Dr.  Martin Levine,
	      M.D., taken in this matter on October 25, 1996.



                                   - 7 -







	23.  The materials that I have reviewed are the type of materials
	     which are customarily relied upon by claims representatives,
	     insurance company claim personnel including those in a
	     supervisory capacity in evaluating the performance of their
	     claims representatives and the appropriateness of the
	     handling of claims by their company.  This type of evaluation
	     was one of my functions in the State Farm SAC unit.  The
	     following subparagraphs of this paragraph of my declaration
	     represent my conclusions and opinions based upon the review
	     referred to in the preceding paragraph:

	   a.  On November 22, 1993 Linda Stoliar was involved in an
	       automobile accident. She was traveling on Benedict Canyon
	       Road in Sherman Oaks when she stopped because a vehicle
	        was backing into the road in front of her.  After she
	       stopped, she was rear-ended by David Cameron. Mrs. 
	       Stoliar was driving a 1989 Honda Wagovan Mr. Cameron was
	       driving a Toyota pick-up. At the time of the impact
	       Mr. Cameron was trying to decelerate from a speed of
	       35-40 miles per hour.

	    b.  Linda Stoliar's vehicle was repaired for $1,014.00 by
	        Foreman Honda. (A shop recommended by Mr. Cameron's
	        insurance  company).  In addition to body work, the
	        repair required four hours of frame straightening. 
	        Mr. Cameron's vehicle was also damaged in the accident.
	        He paid $500.00 (the deductible) and his insurance
	        company, Allstate, paid approximately $1,400.00 for
	        the repair.  Initially, Linda sought treatment from
	        Dr. Martin Bennett with complaints of neck pain and
	        right shoulder pain. She was examined and x-rays were
	        taken of the cervical spine which showed loss of normal
	        cervical lordotic curve in the neutral lateral position,
	        changes consistent with regional musculoligamentous
	        spasm. The x-rays were negative for fracture or
	        dislocation. X-rays of the right shoulder were negative
	        for fracture or dislocation as well.  Conservative
	        treatment was prescribed. However, conservative treatment
	        did not resolve the symptoms so Dr. Bennett recommended
	        an MRI of the cervical spine due to Linda's persistent
	        pain and headaches.

	    c.  On December 14, 1993 Mrs. Stoliar had an MRI of the
	        cervical spine which showed that there was a 3 millimeter
	        left of center subligamentous herniation at C5-C6
	        indenting the anterior aspect of thecal sac. Dr. Bennett
	        has opined that this herniation was a direct result of
	        the auto accident. On May 16, 1994 she had an MRI of
	        the head to rule out intercranial bleeding as she
	        still had prolonged headaches. She was released on
	        July 7, 1994 by Dr. Bennett who stated as follows:

		"The prognosis remains guarded due to the fact that
	        the patient may have headaches and neck pain for the
	        rest of her life and that the natural history of



                                   - 8 -







	        musculoligamentous sprains and strains can, in a
	        significant percent age of people, show patterns
	        of remission and exacerbations over a long period
	        of time."

	    d.  Mr. Cameron's carrier (Allstate) conceded responsibility
	        for the loss and reimbursed Linda Stoliar for the
	        property damage to her vehicle. One week after the
	        accident, Richard Lonie, the State Farm Claims
	        Representative handling the claims, determined that
	        Mr. Cameron was 100% at fault and that Linda Stoliar
	        was 0% at fault and communicated that information to
	        her on the same day.  According to the Allstate records,
	        Allstate also determined that Mr. Cameron was 100% at
	        fault and communicated this to Mr. Cameron.  Before
	        any claim was made, State Farm sought and obtained a
	        signed authorization to copy Linda Stoliar's medical
	        and employment records by December 3, 1993. A review
	        of the files of Linda Stoliar's treating doctors show
	        that State Farm never used this authorization to copy
	        or obtain any medical records until January of 1995
	        when it was used to obtain a copy of Dr. Bennet's
	        records. No other records were copied with this
	        authorization.

	   e.  The diagnosis of Mrs. Stoliar's health care providers
	       was cervical sprain, right shoulder sprain, right sided
	       radiculopathy, cervical concussion, 3 mm subligamentous
	       disc herniation and post traumatic headache, all the
	       result of the November 22, 1993 accident. Mrs.  Stoliar
	       incurred a total of $14,448.29 in medical specials.

	   f.  Mrs. Stolair's State Farm auto policy provided that
	       State Farm was to pay $10,000.00 of medical payments
	       regardless of fault.  In the summer of 1994, having
	       paid less than the $10,000.00 provided for in the
	       policy, State Farm commenced denying payment of
	       doctors' bills submitted to it.  by Linda Stoliar's
	       healthcare providers.  No reason was given for
	       these denials.

	   g.  Subsequently, in January of 1995 State Farm acknowledged
	       by letter that it knew that the $10,000.00 medical
	       payments coverage limit had not been exhausted. Still,
	       State Farm did not pay the remaining medical expenses. 
	       It was not until written demand was made by plaintiff's
	       counsel in March of 1995 that State Farm finally paid
	       the remainder of the $10,000.00 medical payments coverage
	       due and owing. At no time did State Farm ever advise that
	       any medical bill submitted was considered by it to be
	       unnecessary, unreasonable or unrelated to the November,
	       1993 accident.

	   h.  Between the date of the accident and January of 1995,
	       State Farm copied no medical records of plaintiff,
	       consulted with no doctors regarding plaintiff's condition


                                   - 9 -







	       and had absolutely no basis for denial of these medical
	       payment benefits. Other than obtaining the medical
	       records of Dr. Bennett in January of 1995, and the
	       records provided by Mr. Rowell in January of 1995 and
	       again in March of 1995, State Farm did not obtain any
	       medical records on Mrs. Stoliar until after it had
	       settled in September of 1995.

	   i.  After she had been released by Dr. Bennett from treatment
	       regarding the first accident, on February 7, 1995 Linda
	       Stoliar was involved in a seco nd vehicle accident.
	       While stopped at an intersection she was struck in an
	       off-set fashion from the rear by a car being driven by
	       Jared Tobman. Although the collision did not cause a
	       great deal of damage to the Stoliar vehicle, because it
	       was an off-set impact from the rear of the vehicle, the
	       Stoliar vehicle was spun about and she began to
	       experience increased neck and back pain. Mrs.  Stoliar
	       sought medical treatment from Dr.  Bennett again. 
	       According to the State Farm claims file, as a result
	       of the second accident she incurred over $6,900.00 in
	       medical expenses. One of the bills that was incurred
	       by Mrs. Stoliar was a MRI of the thoracic spine which
	       had been ordered by Dr. Bennett which was conducted in
	       March of 1995 after her persistent back pain remained
	       unresolved from conservative treatment. The MRI was
	       ordered as a result of the second accident. The bill
	       for the MRI was submitted to State Farm which refused
	       to pay it. After refusing to pay this bill and those
	       of Linda Stoliar's doctor, Martin Bennett, State Farm's
	       Claims Representative, Ann Spratt, contacted Dr. Bennett,
	       who advised that the bills were incurred as a result
	       of the accident of February, 1995.  This conversation
	       occurred on April 19, 1995. Still, State Farm refused
	       to pay the MRI bill. State Farm then advised it was
	       going to submit the MRI to a doctor for review to
	       determine whether it was reasonable and necessary.
	       However, State Farm never asked the doctor is selected,
	       Dr. Martin Levine, to review the MRI or the medical
	       records to determine whether or not the charge or the
	       treatment with respect to the MRI was appropriate. At
	       his deposition Dr.  Levine testified that the charge
	       and the treatment was appropriate.  Nonetheless, State
	       Farm refused to pay for the MRI until October of 1995
	       and then only on condition that Linda Stoliar settle
	       her bodily injury claim for $1,000.00.

	   j.  State Farm claims never to have evaluated either of
	       Mrs. Stoliar's claims before September 14, 1995.
	       However, State Farm determined that the other driver was
	       100% at fault with respect to both claims and never
	       offered anything to settle either claim until September
	       of 1995 when it offered its policy limits of $10,000.00
	       with respect to the November 22, 1993 claim and October,
	       1995 when it agreed to pay the MRI bill and $1,000.00 of
	       uninsured motorist benefits with respect to the
	       February 7, 1995 claim.

                                   - 10 -







	   k.  The failure of State Farm to evaluate either of these
	       claims within a shorter time period was a direct result
	       of a company policy that was implemented in approximately
	       1993. This policy was applied to this case based on the
	       fact that the State Farm appraisal of the damage to the
	       Stoliar vehicle was less than $500.00, even though
	       State Farm knew that the actual damage to the vehicle
	       exceeded $1,000.00. Pursuant to the terms of the company
	       policy a "minor impact" or "low damager" designation was
	       applied to cases where the amount of property damage to
	       the insured's vehicle was "minimal" (usually $500.00 or
	       less). When a case was so categorized, State Farm would
	       take a "hard ball" position regardless of the merits of
	       the claim, refuse to make any reasonable settlement
	       offer and force the matter to a formal arbitration or
	       litigation. In addition, in order to make handling such
	       claims for plaintiffs as costly as possible, State Farm
	       would require its attorney to employ formal discovery
	       devices, retain biomechanical experts and accident
	       reconstructionists in all of these "low damager" cases.

	   l.  This policy was coupled with a company directive that
	       the claims representative personnel were to advise all
	       counsel that State Farm would not settle these cases and
	       would "fully litigate" them.  As indicated in the
	       evidence submitted herewith the goal and stated purpose
	       of this company policy, which was disseminated amongst
	       the legal community at company direction by the claims
	       representatives and other persons working for State Farm,
	       was to discourage the presentation of such claims and to
	       discourage attorneys from representing claimants on
	       these "minor impact"/"low damager" claims by making it
	       virtually financially impossible for a claimant in such
	       a case to obtain representation. This company policy had
	       its desired long term effect.

	   m.  According to the State Farm superintendent in charge of
	       the unit which handled the Stoliar claim, the claim
	       representative who worked on the claim were well aware
	       that they had an obligation under the insurance code and
	       their policy of insurance, to attempt to effectuate fair
	       reasonable and prompt settlements. However, as a result
	       of Mrs. Stoliar's claims being classified as "minor
	       impact"/"low damager" no effort was made to settle this
	       case or make any offer or even evaluate the case until
	       the middle of September of 1995 almost two years after
	       the initial accident and seven months after the second
	       accident. Further, because the second accident was
	       classified as a "minor impact"/"low damager" case, no
	       effort was ever made to evaluate it and no effort was
	       ever made with respect to settlement, even though over
	       $6,900.00 in medical expenses were incurred by Mrs. 
	       Stoliar as a result of the second accident.





                                   - 11 -







	   n.  Thus, liability was clear, and that State Farm had
	       conceded that the treatment (with the exception of the
	       MRI of March 1995) was reasonable, necessary and
	       related to each accident (by paying the medical bills). 
	       Nonetheless, State Farm claims that no evaluation was
	       made and no offer extended until September 1995. Any
	       reasonable Claims Representative, not bound by the
	       "low damager" policy would conclude the claim for the
	       UIM benefits exceeded the policy limits.  Further, in
	       my opinion, the refusal to attempt to settle "low
	       damager" cases in a fair, reasonable and prompt manner
	       was a deliberate company policy arbitrarily implemented
	       on a region-wide basis without regard to the merits of
	       individual claims.

	  o.  Additionally, because of plaintiff's psychiatric history
	      and condition, according to her treating mental health
	      care providers, State Farm's conduct on this file was
	      much more destructive, contributing to the deterioration
	      of plaintiff, suicide attempts and psychiatric
	      hospitalizations during 1995.

	I declare under penalty of perjury pursuant to the laws of the
	State of California, that the foregoing is true and correct.

	Executed this 11th day of November, 1996 at Glendale, California.

	Amy Girod Zuniga, Declarant


	Footnotes
	(1) In a signed statement by Mr. Cameron dated December 6, 1993,
	    which was contained in the State Farm claims file,
	    Mr.  Cameron admitted that he was traveling at 35 miles
	    per hour before the accident.

	(2) This was a curb-side "eyeball" appraisal by a State Farm
	    employee.




















                                   - 12 -


	_______________________________________________________________




Top of Page
Home Page
Insurance Page
Uncivilization and its Discontents
Essay Page

Email me, Bill Hammel at
bhammel AT graham DOT main DOT nc DOT us
READ WARNING BEFORE SENDING E-MAIL


The URL for this document is:
http://graham.main.nc.us/~bhammel/RICO/Zuniga.html
Created: February 4, 2000
Last Updated: May 28, 2000