Party Statement: Koop vs Fire Insurance Exchange, dba Farmers Insurance Group

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                                1   ALBERT M. T. FINCH, III, ESQ. State Bar # 196478
     JASON DENG, ESQ. State Bar # 336941
 2   FORAN GLENNON
 3   1741 Technology Drive, Suite 250
     San Jose, CA 95110
 4   tfinch@fgppr.com
     jdeng@fgppr.com
 5   Telephone: (669) 317-4285
 6   Facsimile: (312) 863-5099
     Attorneys for Defendant BRIAN HUNSAKER
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                           SUPERIOR COURT OF THE STATE OF CALIFORNIA
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                                 IN AND FOR THE COUNTY OF SONOMA
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10   GARY KOOP                                        CASE NO. SCV-266944
11                          Plaintiffs,               DECLARATION OF ELIZABETH MONICA
12             vs.                                    EVANS IN SUPPORT OF DEFENDANT
                                                      BRIAN HUNSAKER’S OPPOSITION TO
13   FIRE INSURANCE EXCHANGE dba                      PLAINTIFF’S MOTION FOR SUMMARY
     FARMER INSURANCE GROUP; BRIAN                    ADJUDICATION
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     HUNSAKER,
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                            Defendants.               Motion Hearing Date: June 28, 2022
16                                                    Time: 3:00 P.M.
                                                      Dept: 19
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18                                                    Action Filed Action Filed: August 24, 2020
                                                      Amended Complaint filed: January 6, 2021
19                                                    Trial Date: November 17, 2023
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22   I, ELIZABETH MONICA EVANS, declare:

23   1.        I am an employee to Brian Hunsaker’s office located at 8741 Old Redwood Hwy, Windsor,

24   CA 95492. The matters stated herein are true and correct of my own personal knowledge unless

25   they are stated to be based on information and belief, and as to those matters, I am informed and

26   believe them to be true. If called upon to testify regarding these matters herein, I could and would

27   competently do so.

28   ///


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           DECLARATION OF ELIZABETH MONICA EVANS IN SUPPORT OF DEFENDANT BRIAN HUNSAKER’S
                     OPPOSITION TO PLAINTIFF’S MOTION FOR SUMMARY ADJUDICATION
 1   2.       I believe one of my professional responsibilities to the customers is when a customer
 2   requests information and/or review of their insurance policies, I need to promptly respond to the
 3   customer’s request by providing either requested information and/or reviewing the policy with said
 4   customer. I have been working in the insurance industry since 1999.
 5   3.       In the call I had with Gary Koop on September 1, 2015 call, I did not tell Gary Koop that he
 6   had “sufficient coverage on the Policy” to rebuild his home as it was ultimately Plaintiff’s
 7   responsibility to determine the sufficiency on the coverage. Mr. Koop requested that certain
 8   attributes of his house be changed on the 360Value Estimate. On Gary Koop’s request, I made the
 9   changes requested and sent him a copy of the modified 360Value Estimate for his review to
10   determine if any further changes were needed.
11   4.       After September 1, 2015, Plaintiff Gary Koop did not contact me again to inquire on
12   whether any further changes to be made on the 360Value Estimate until after the loss of the
13   property from the wildfire in 2017.
14   I declare under penalty of perjury under the laws of the State of California that the foregoing is true
15   and correct.
16   Executed on June ________, 2023 in Windsor, California.
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                                                          _____________________________
19                                                        ELIZABETH MONICA EVANS
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          DECLARATION OF ELIZABETH MONICA EVANS IN SUPPORT OF DEFENDANT BRIAN HUNSAKER’S
                    OPPOSITION TO PLAINTIFF’S MOTION FOR SUMMARY ADJUDICATION