E-FILED - SC Superior Court E-Filing

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The Doan v. State Farm General Insurance Company Appendix 4 Analysis of Basis For Depreciation Used For Claim Settlement Key Word Search of Activity Logs - Key Word: "Condition" Claim Contains "Condition" in Context of Depreciation Claim No. Activity Log No. Date of Activity Log Entry Excerpt Containing Key Word / Phrase Bates No. 31 75-M446-682 20 11/21/2005 INSPECTION RESULTS: Inspected loss w/Mr. PH. Water damage to basement caused by icemaker line in ceiling that burst. PH had a sattel valve connected to a 1/2" cold water pipe in basement ceiling that fed the ice maker in the refrig. directly above basement. Plastic line feeding icemaker burst and flooded basement. PH stated line was approx. 4 years old. However, due to the condition of the basement valve and line were extremely worn there is No possibility for sub due to the condition of the valve and line. Water damaged acoustical suspended ceiling and flooded entire basement. PH had several Personal Property items stored in basement. Service master thru PSP completed drydown. Water also damaged paint on foundation walls and floor. SF_CL0002914 32 75-M446-682 19 11/21/2005 Received call from CR Weatherby, he picked up the part and it is rusted may be due to age or conditions of basement. He will dispose as there is no subrogation potential. SF_CL0002914 1 33 75-M596-075 164 12/1/2010 TIC to Thomas Rug Cleaning Co & slw Harry. Reviewed the following with him: 1. Invoice #130950 $1760.00 rug cleaning has not been paid. 2. Only 1 rug was cleaned (5x9'8" Caucasian $220.00) & it did not come clean so he did not bother to clean the others as it was not cost effective considering the damage & the cleaning cost vs. the replacement cost.He's never rec'd any add'l direction from the insured. 3. Questioned regarding his appraisal for replacement of rugs & the condition of each rug. If not cleaned how will does he know final outcome? Said he's basing it on results of first attempt. Agreed he would not attempt to clean the rugs that had obvious bum marks on them. 4. Has had the rugs since August & PH was corning in often to inquire about his rugs but has not seen him in over a month once Harry started pushing for pymt of storage fees. 5. Asked what condiditon the rugs were in when he rec'd them. Is all this damage from the fire, or could it be wear & tear? Harry states that the color fading could be from sun exposure (PH told him fire dept put rugs outside), the heat of the fire causes the dyes to "loosen" up so they fade & run, and wear & tear from use. All three factors probably contributed to condition of rugs. 6. The rugs are still in his shop. He needs to start charging storage fees as they take up a bunch of space and it's been 5 months. Fees are $100/month. 7. Reviewed salvage value, due to downturn in market there is not much demand for new rugs let alone damaged rugs. There is some value but the cost to sell would exceed their value. He last sold a "new" rug 3 months ago & is staying afloat with their cleaning & repair services. 8. Asked if the condition of the rugs would continue to deteroriate after being rolled up for 5 months. Hany states no that the damage stays the same and they would not have cleaned up better then vs. SF_CL0002752 34 75-M596-075 23 8/10/2010 now * The House was in average/good condition and he agreed. PA Is going to work on the PPIF. SF_CL0002784 1 35 75-M629-365 11 6/22/2011 .. Informed OCR has sent PPIFs to complete to document loss - need age, RC and condition. SF_CL0002728 36 75-M586-307 189 9/29/2011 OAR, Continue to work with insured to resolve outstanding items; confrim your conversations with insured in writing and quote the appropriate Conditions language in letter. SF_CL0002638 37 75-M586-307 154 11/29/2010 Action plan to address issues outstanding: 1) Retain consulting GC to detach the center island and coordinate the detach and reset of the Wolf Range. 2) Finmark to detach the newly laid flooring to exposed the subfloor 3) Insured's GC, consulting GC, insured, and CR to meet and determine cause of the swelling to the flooring. 4) If subfloor is cause of swelling, insured's GC to repair. If flooring, Finmark to address re-install. If preexisting conditions it will be the insured's responsibility. Items detached will be reset. 5) Conclude handling accordingly SF_CL0002644 10/15/2012 5
The Doan v. State Farm General Insurance Company Appendix 4 Analysis of Basis For Depreciation Used For Claim Settlement Key Word Search of Activity Logs - Key Word: "Condition" Claim Contains "Condition" in Context of Depreciation Claim No. Activity Log No. Date of Activity Log Entry Excerpt Containing Key Word / Phrase Bates No. 38 75-M586-307 64 6/7/2010 -Insured is stating they relied on SF as the previous CR did not offer and they had no knowledge on what to do next, the insured stated the previous CR had also stated to them if their EWS company billed too much or took too long SF would not pay them and they would be responsible for the billing. Insured stated she did not appreciate theway the claim was handled before and now with the condition of her home, no kitchen and with kids who have respiratory problems this is taking way too long. 39 75-M586-307 32 5/18/2010 Note: ph has high end hospital grade air filters and UV lights for the HVAC due to ph children health conditions. 40 75-M586-307 25 5/18/2010 CR received call from PH. PH concerned that we did not assign EWS the first time she called in. CR explained CR is not sure why EWS was not sent during QFC as it should have been done. CR explained the good thing is EWS is going out there now and there is coverage for ensuing damages. PH said she is concerned because there may be mold underneath the kitchen floor. She has 2 children with allergies and has been running the air conditioning. CR explained she should be ok right now as she is not actually sure there is mold and if there is the mold is under the floor and is not being blown around by blowers and has not been touched by anyone living in home. PH understood and asked how the claim process works from here. CR explained when SP comes out they will run a mold test, if there is mold they will abate the mold and depending on how much mold they find they will do a test to make sure it is gone. CR told PH she is able to go to a hotel during mold abatement if necessary. PH understood. PH then asked what she should do if she wants to use her own mold person after SP sends theirs. Should she call back in? CR said yes to call in and talk to us if she is not satisfied with SP's company. PH also asking if SP is going to take up her floors when they go out. CR explained SP will evaluate what they need to do when they get there. PH understood. 41 55-E078-594 63 9/15/2009 Called Dan, 916 987-0400. He said HVAC cleaning company went out and discovered ductwork in such poor condition that cleaning would be pointless. Very light soot required cleaning, condition of ducts require replacement. Replacement estimate $1440. they will proceed with Ozone & balance of cleaning throughout. 42 55-E078-594 58 9/14/2009 Called steve with ServPro, discuused status and issues with resident relative health concerns. He said with amount of direct fire damage to bedroom, it is reasonable to conclude that smoke traveled throughout the risk. With relative's heart condition it is likely that residual smoke odor would not be able to be extracted with cleaning. He would not want to assume liability for future health issues. Also discussed HVAC cleaning . He will get sub-bid as they do not have equipment for duct cleaning. 43 55-E078-594 20 8/17/2009 COVERAGE C: I do not believe that Coverage C is needed in this case, the smoke smell is not bad to me and I could not smell it in the house except for the bedroom of origin. It is a possibility with the insured's mother living there and having a heart condition that there is a problem for her with her sensitivity, her doctor may need to decide that. 44 55-F999-246 87 10/27/2008 C: Rec'd c/b from Atty Karen Rosensweig via 55-F998-372. Atty advised payments have been "frozen" b/c two claimants (one Karen thinks is SF/insd Shannon but doesn't have claim # and she's not handling, other is for $150K) are not signing release. We already signed release but it is conditioned upon all claimants completing. Set 3 month diary. T: flu with atty for status; is litigation commencing b/c of non-coop of two claimants? SF_CL0002660 SF_CL0002667 SF_CL0002669 SF_CL0002616 SF_CL0002617 SF_CL0002624 SF_CL0002578 10/15/2012 6
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E-FILED: Oct 15, 2012 5:00 PM, Supe
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