E-FILED - SC Superior Court E-Filing

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