E-FILED - SC Superior Court E-Filing
E-FILED - SC Superior Court E-Filing
E-FILED - SC Superior Court E-Filing
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E-<strong>FILED</strong>: Oct 15, 2012 5:00 PM, <strong>Superior</strong> <strong>Court</strong> of CA, County of Santa Clara, Case #1-08-CV-129264 <strong>Filing</strong> #G-47834<br />
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Assignment<br />
6. I have been retained by Plaintiffs’ counsel to evaluate the economic impact of<br />
State Farm’s alleged wrongful conduct. More specifically, and for purposes of this declaration, I<br />
have been asked to determine (1) the extent to which State Farm used a standard estimating<br />
system known as the “Depreciation Guide” to set the depreciation used in settling policy holder<br />
claims, and (2) whether the actual physical condition of the claimed item as of the time of loss is<br />
documented in State Farm’s claim files.<br />
Data Used For Analysis<br />
7. I obtained from Plaintiffs’ counsel claim files produced by State Farm (“Claim<br />
Files”) that contain, inter alia, (1) a Contents Inventory Summary (“CIS”) form, (2) an Activity<br />
Log and (3) a Personal Property Inventory Form (“PPIF”). In addition, I received from Plaintiffs’<br />
counsel State Farm’s depreciation guide (“SF Depreciation Guide”).<br />
8. I also received from Plaintiffs’ counsel an electronic database, which I understand<br />
was compiled by Plaintiffs’ counsel based on data contained in the Claim Files (“Claim File<br />
Database”). Specifically, the Claim File Database contains data obtained from the CIS forms and<br />
PPIFs listed above that were contained within Claim Files that State Farm produced. I understand<br />
that Plaintiffs’ counsel is continuing to receive claim files from State Farm and is adding<br />
additional data to the Claim File Database as Claim Files are received from State Farm. My<br />
analysis as set forth in this declaration is based on data available to me as of the date of my<br />
declaration. I will update my analysis based on additional data obtained from Plaintiffs’ Counsel.<br />
To confirm that the data contained in the Claim File Database accurately reflects the data<br />
contained in the underlying source documents, I and staff working under my direction and<br />
supervision audited selected records contained in the Claim File Database. Our audit work<br />
consisted of reviewing the underlying source documents to confirm the data in the Claim File<br />
Database were entered correctly. This audit consisted of the following steps:<br />
� For CIS data located in “Tbl_SF_Inventory”:<br />
o Reviewed each record to ensure the accuracy of fields “Item<br />
Desc/Mfg,” “Settlement Option,” “Repair/Replacement Cost,”<br />
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Declaration of Bruce McFarlane In Support of Motion For Class Certification