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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“Depr %,” and “Depreciation Amount.”
o Compared the data in these fields to the most recent CIS available
within the claim file.
o For any record found to contain inaccurate or incomplete
information as compared to the most recent CIS, updated relevant
field(s). 4
� For PPIF data located in “Tbl_PPIF”:
o Reviewed each record to ensure the accuracy of fields “Item
Condition,” “Item Age or Purchase Date,” “Replacement Repair or
Restoration Cost,” “Today’s Value,” and “Value.”
o Compared the data in these fields to the PPIF found within the
claim file.
o For any record found to contain inaccurate or incomplete
information as compared to the PPIF, updated relevant field(s).
42.1 Percent Of Claimed ACV Items Reviewed Contain Depreciation Amounts That Match
The Applicable Depreciation Per The SF Depreciation Guide; 81% Of Claim Files
Reviewed Contain Depreciation Amounts That Match The Applicable Depreciation Per The
SF Depreciation Guide
9. To evaluate 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, I
analyzed the depreciation State Farm used to settle ACV personal property claims per the CIS
forms vis-à-vis the depreciation indicated based on the SF Deprecation Guide. Because both the
age and State Farm’s depreciation of the item are required to use the SF Depreciation Guide, I
could only include those claim files that have both a CIS and a PPIF. To perform this analysis, I
performed the following steps:
� From the Claim File Database, I obtained a listing of claimed items where
the settlement option was equal to “Actual Cash Value” (“ACV Settlement
Items”); 5
� From the SF Depreciation Guide, I prepared a schedule that listed
depreciation amounts by classification and subclassification (“SF
4
Our review revealed that, for many records, the “Item Desc/Mfg” field had been summarized or
truncated. We updated this field in each instance where we determined that the additional
information from the CIS form would be useful in our subsequent matching of the item to a
specific category on the SF Depreciation Guide.
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See ACV Settlement Items list at Appendix 5. This step resulted in identifying 2,551 claimed
items from 40 claim files. Of these, 1,826 claimed items from 37 claim files included a known
age greater than zero.
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Declaration of Bruce McFarlane In Support of Motion For Class Certification