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. 58 75-M624-390 22 5/6/2011 PH has very expensive Ethan Allen furniture. PH presented pH with copies of receipts for most items, well over $20,000 worth of just furnishing. Damage to bedframe in bedroom, informal table & chairs, brown leather couch & sofa, end tables, china hutch, formal dining chairs, formal dining table has metal feet, may be saved. Buffet damaged, white leather sofa has removable wood feet and may be saved. PH has antique red velvet love seat she brought from India. PH unsure of value - is very high quality and in excellent condition. CR will see if wood feet can be restored. CR viewed her furniture items at off site storage as well as several items in her garage. PH also has several pairs of shoes and inexpensive throw rugs affected. PH also had a larger arear rug aprox $700 value soaked and thrown out. CR provide PH with $10,000 advance for Cov B so PH can start to order replacement furniture items. PHs funiture was all in excellent and nearly new condition so depreciation will be minimal. PH has some clothing items that SP picked up, may be laundered and sanitized but may also be total loss. SP to itemize. SP to clean and sanitize furniture that can be cleaned, they will check into replacing feet on dining table & white leather sofas & matching chairs. 59 75-M456-650 12 7/31/2007 * Advised that many of the items on the list are lumped together and we would need these items broken out and priced individually. Again pointed to the recovery of RC benefits as the basis for the request, as well as the policy conditions. She understood. 60 55-E116-561 45 4/15/2011 Please contact the PH. Arrange a re-inspection of the carpet. PH claims they attempted to professionally clean the carpet but did not come clean. Please verify the condition of the carpet. If uncleanable obtain ITEL sample and then complete replacement estimate. 61 75-M613-624 287 4/26/2012 It is my concluding opinion that the water line was improperly installed causing excessive stress to the water line, a condition which led to the incident water damage. Had the line been installed without excessive induced stress in the line, the water damage incident would have been avoided. 62 75-M613-624 175 5/23/2011 Salvage: Pends evaluation of TOSCO evaluation (log 79). The items that were marked salvagable were not repairable as they cannot be put back/repaired to their pre-loss condition. Salvage takes into consideration that some parts may have parts value only. Kari advised she intends on bringing buyer to PH's business location for salvage purposes/purchases. 63 75-M613-624 172 5/23/2011 - SALVAGE ACTION PLAN: Salvage pends evaluation of TOSCO evaluation (log 79). The items that were marked salvagable were not repairable as they cannot be put back/repaired to their pre-loss condition. Salvage takes into consideration that some parts may have parts value only. Kari advised she intends on bringing buyer to PH's business location for salvage purposes/purchases. 64 75-M613-624 118 4/5/2011 SUBRO/SALVAGE COMMENTS: Salvage: Pends evaluation of TOSCO evaluation (log 79). The items that were marked salvagable were not repairable as they cannot be put back/repaired to their pre-loss condition. Salvage takes into consideration that some parts may have parts value only. Kari advised she intends on bringing buyer to PH's business location for salvage purposes/purchases. 65 75-M613-624 89 3/15/2011 SUBRO/SALVAGE COMMENTS: Salvage: Pends evaluation of TOSCO evaluation (log 79). The items that were marked salvagable were not repairable as they cannot be put back/repaired to their pre-loss condition. Salvage takes into consideration that some parts may have parts value only. Kari advised she intends on bringing buyer to PH's business location for salvage purposes/purchases. SF_CL0001999 SF_CL0001930 SF_CL0001890 SF_CL0001740 SF_CL0001765 SF_CL0001767 SF_CL0001778 SF_CL0001785 10/15/2012 9
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. 66 75-M613-624 79 3/10/2011 Called and spoke with Kari C#. The items that were marked salvagable were not repairable as they cannot be put back/repaired to their pre-loss condition. Salvage takes into consideration that some parts may have parts value only. Kari advised she intends on bringing buyer to PH's business location for salvage. We discussed the 3 dental chairs and the letter submitted by Patterson. Kari said the letter is incorrect. Kari said her inspection of the chairs revealed all 3 were damaged and described damage as Dr Goto did (see log 78). I advised I have called Patterson Dental requesting clarification. 1 67 75-M613-624 70 3/1/2011 - PH has reviewed the depreciation (actual cash value) for the BPP. PH agrees that the applied depreciation is appropriate based on age, condition, and use of the item. 68 75-M613-624 69 2/28/2011 Spoke with Dr Goto and discussed depreciation for BPP. Dr Goto will be replacing most items, he has in fact began replacing items and will continue to do so. I advised our initial payment is based on ACV for the items explaining ACV based on age and condition of item. I advised TOSCO has confirmed ages and condition of items based on their inspection and expertise in PH's type of BPP/equipment. I advised I wanted to make sure the depreciation was accurately/appropriately applied. PH understood. PH said he will review the TOSCO inventory for depreciation and advise if applied appropriately and/or if adjustments should be made as condition may may be different than applied. 69 75-M613-624 66 2/21/2011 OAR. Rev'd file & RFA. Pls clarify when and with whom we reached agreement "regarding age, use and condition" referenced in log 62. Pls clarify why ACV in log 64 is not consistent with ACV in TOSCO rpt. Lastly, pls comment on why salvageable items in the TOSCO rpt are not being considered for repair vs. replacement. Pls resubmit RFA w/in 10 days and close COL 67 if we do not anticipate any LOI pmts. 70 75-M613-624 62 2/18/2011 Contents Inventory review: CP inadvertently input $92,500 for each of the 3 dental chairs rather than $92,520.16 total (see items 64,65,66). Contents Inventory for all other items accurately reflects the RCs provided by PH and applies depreciation based on agreement with PH regarding age, use and condition. 71 75-R295-811 20 3/12/2009 Met with Raymond Pena the insured son on 03/11/09 and inspected the property. The son and his family live at the home, at the time of inspection there were three adults and one child. The insured Mr. Bertram Pena lives there and in New Mexico. He comes to this location approximately every 6 weeks per his son Raymond. The home is in poor condition. There is a water stain in the living room from the roof leaking. The insured states the roof has been repair but at the time of inspection there were still missing shingles off the front of the home. The family room's floor has been partially removed and the insured stated they are trying to determine what kind of floor they would like to put down. The attic had evidence of rats in the attic with rat droppings. 72 75-M477-648 50 4/12/2007 At this time, we do not have sufficient information to Substantiate insured's proof of loss. In my inspection of January 15, 2007, other than your concern for the condition of a home computer, insrued indicated to me that heu did not believe there were any damages to your personal contents. Since he ise now making claim for additional damages, we will need to schedule an inspection to continue our investigation of your claim. We are awaiting insured's return call for re-ispection. Regarding estimate of $750 to repair your stucco/plaster, our record indicates we have already paid $416.16 ($346.80 + 20% for OH&P) based on Disaster Kleen up's estimate. Dictate a status letter with duties. Extended duties to June 12, 2007. SF_CL0001787-88 SF_CL0001790 SF_CL0001790 SF_CL0001791 SF_CL0001793 SF_CL0001723 SF_CL0001708-09 10/15/2012 10
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