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1 Stacy M. Tucker (SBN 218942)
smtucker@mtlawpc.com
2 MONAHAN TUCKER LAW, PC
14241 NE Woodinville-Duvall Road
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Suite 382
4 Woodinville, WA 98072
T: (206) 486-3553
5 F: (206) 339-7155
6 Lisa S. Kantor (SBN 110678)
lkantor@kantorlaw.net
7 KANTOR & KANTOR, LLP
19839 Nordhoff Street
8 Northridge, CA 91324
T: (818) 886-2525
9 F: (818) 350-6272
10 Attorneys for Plaintiff, Gary Koop
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SUPERIOR COURT OF THE STATE OF CALIFORNIA
14241 NE Woodinville-Duvall Road, Suite 382
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COUNTY OF SONOMA
MONAHAN TUCKER LAW, P.C.
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Woodinville, WA 98072
(866) 823-8275
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Case No.: SCV-266944
15 GARY KOOP, [Assigned for All Purposes to the
Plaintiff, Honorable Jane Gaskell]
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v.
17 DECLARATION OF STACY TUCKER
FIRE INSURANCE EXCHANGE, dba IN SUPPORT OF PLAINTIFF’S
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FARMERS INSURANCE GROUP; BRIAN MOTION TO AUGMENT EXPERT
19 HUNSAKER, DISCLOSURES
Defendants.
20 Date:
Time:
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Dept: 7
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23 Action Filed: August 24, 2020
Trial Date: March 29, 2024
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DECLARATION OF STACY TUCKER
1 I, Stacy Tucker, declare as follows:
2 1. I am an attorney at law duly licensed to practice before all courts in the State of
3 California and am a partner at the law firm of Monahan Tucker Law, P.C., attorneys for Plaintiff,
4 Gary Koop. I make this Declaration on behalf of Plaintiff Gary Koop in relation to his Motion for
5 Summary Adjudication in this action. I have personal knowledge of the facts stated herein and, if
6 called upon to testify, could and would competently testify thereto.
7 2. Plaintiff Gary Koop bases the calculation of his breach of contract damages on the
8 delta between the value of the insurance coverage calculated by 360Value for his Property when
9 listed as “above average” quality grade and when listed as “premium” quality grade. The parties
10 have conducted discovery on this issue and met and conferred, and all parties agree that there is no
11 way in 360Value to determine what the exact amount of coverage would have been for his Property
14241 NE Woodinville-Duvall Road, Suite 382
12 as “premium” quality grade in 2017, because 360Value updates it databases in real time.
MONAHAN TUCKER LAW, P.C.
13 3. Plaintiff timely provided his expert disclosures on September 28, 2023. A true and
Woodinville, WA 98072
(866) 823-8275
14 correct copy of those disclosures is attached as Exhibit 1.
15 4. In January 2022 and March 2023, I went to the Farmers website at
16 https://www.farmers.com/ to determine what the coverage would be for Plaintiff’s Property when
17 calculated at the “above average” quality grade and then at “premium” quality grade. I took screen
18 shots of each page created in running both scenarios. In Plaintiff’s oppositions to the motions for
19 summary judgment filed by each defendant, I relied on the 2022 screenshots to demonstrate
20 Plaintiff’s contract damages. In Plaintiff’s motions for summary judgment against each Defendant,
21 I relied on the 2023 screenshots to demonstrate Plaintiff’s contract damages. These declarations and
22 screenshots are attached to the Request For Judicial Notice filed with Plaintiff’s Motion and this
23 Declaration.
24 5. When I prepared Plaintiff’s expert disclosures in September 2023, I intended to have
25 Brian Hunsaker, on the witness stand, use a laptop connected to the Court’s larger screen to access
26 the Farmers website in front of the jury, and run those scenarios in real time to demonstrate and
27 authenticate the two scenarios and their difference. For that reason, I did not designate an expert to
28 opine as to the difference in coverage between the two quality grades.
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DECLARATION OF STACY TUCKER
1 6. On November 3, 2023, the parties filed a joint stipulation asking the Court to
2 postpone the November 17, 2023 trial date while a new judge was assigned and the pending motions
3 for summary judgment were ruled upon. That stipulation agreed to tie the deadline for taking expert
4 depositions to the new trial date to be assigned by the Court.
5 7. On or about November 6, 2023, I went to https://www.farmers.com/ again to run
6 updated scenarios. I learned at that time that at some point between March 2023 and November 6,
7 2023, Farmers disabled the ability for California homeowners to obtain quotes on their residences.
8 Other states can still obtain an automatic quote, but entering a California results in instructions to
9 contact a Farmers agent to obtain a homeowners insurance quote. I therefore was no longer able to
10 proceed with my prior plan to ask Brian Hunsaker to run scenarios on the stand in order to
11 authenticate the scenarios.
14241 NE Woodinville-Duvall Road, Suite 382
12 8. On November 7, 2023, I contacted Kevin Hromas, an insurance appraiser who had
MONAHAN TUCKER LAW, P.C.
13 been previously recommended to me as a potential expert for this subject. He agreed to serve as an
Woodinville, WA 98072
(866) 823-8275
14 expert.
15 9. On November 12, 2023, I prepared Plaintiff’s proposed augmented expert
16 disclosures. A true and correct copy of these proposed disclosures is attached as Exhibit 2.
17 10. On November 12, 2023, I served Plaintiff’s proposed augmented expert disclosures
18 on all parties and asked to meet and confer about whether they would stipulate to the inclusion of
19 Mr. Hromas, or if Plaintiff would need to file a motion to augment. A true and correct copy of that
20 email is attached as Exhibit 3.
21 11. On November 13, 2023, counsel for Farmers responded with a letter declining to
22 stipulate and providing Farmers’ basis for its refusal. Counsel for Hunsaker has not responded to
23 Plaintiff’s proposed augmented disclosures. A true and correct copy of the November 13, 2023 letter
24 I received from Farmers’ counsel Steven Inouye is attached as Exhibit 3.
25 12. No expert depositions have been taken in this matter and none are currently
26 scheduled.
27 ///
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3
DECLARATION OF STACY TUCKER
1 I declare under penalty of perjury that the foregoing is true and correct and that this
2 Declaration was executed on November 17, 2023, at Woodinville, Washington.
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4 _______________________________
Stacy M. Tucker
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14241 NE Woodinville-Duvall Road, Suite 382
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MONAHAN TUCKER LAW, P.C.
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Woodinville, WA 98072
(866) 823-8275
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DECLARATION OF STACY TUCKER
EXHIBIT 1
EXHIBIT 1
1 Stacy M. Tucker (SBN 218942)
smtucker@mtlawpc.com
2 MONAHAN TUCKER LAW, PC
14241 NE Woodinville-Duvall Road
3
Suite 382
4 Woodinville, WA 98072
T: (206) 486-3553
5 F: (206) 339-7155
6 Glenn R. Kantor (SBN 122643)
gkantor@kantorlaw.net
7 KANTOR & KANTOR, LLP
19839 Nordhoff Street
8 Northridge, CA 91324
T: (818) 886-2525
9 F: (818) 350-6272
10 Attorneys for Plaintiff Gary Koop
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SUPERIOR COURT OF THE STATE OF CALIFORNIA
12
14241 NE Woodinville-Duvall Road, Suite 382
COUNTY OF SONOMA
13
MONAHAN TUCKER LAW, P.C.
Woodinville, WA 98072
14 GARY KOOP, Case No.: SCV-266944
(866) 823-8275
Plaintiff, [Honorable Oscar Pardo – Dept. 19]
15
v.
16 PLAINTIFF GARY KOOP’S
DESIGNATION OF EXPERT
FIRE INSURANCE EXCHANGE, dba
17 WITNESSES PURSUANT TO C.C.P.
FARMERS INSURANCE GROUP; BRIAN
§2034.260; DECLARATION OF
18 HUNSAKER,
COUNSEL IN SUPPORT THEREOF
Defendants.
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Action Filed: August 24, 2020
25 Trial Date: November 17, 2023
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PLAINTIFF GARY KOOP’S EXPERT DESIGNATIONS
1 TO ALL PARTIES AND TO THEIR COUNSEL OF RECORD:
2 PLEASE TAKE NOTICE that Plaintiff Gary Koop (hereinafter “Plaintiff”) hereby submits the
3 following list of witnesses whom he intends to call as experts at the time of trial. This designation
4 of expert trial witnesses is made pursuant to Code of Civil Procedure Section 2034.210 et seq. This
5 designation is made with the express reservation of all rights under Section 2034.210 et seq.,
6 including the right to amend or supplement this designation as may be necessary.
7 Defendant may call the following experts pursuant to the Code of Civil Procedure Section 2034.260
8 for the purpose of forming and expressing an opinion:
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10 I. EXPERT WITNESSES
11 1. David Bano
AES Consulting Group, Inc.
12 626 Avenida de Mayo
14241 NE Woodinville-Duvall Road, Suite 382
Sarasota, FL 34242
13 Telephone (614) 519.5389
MONAHAN TUCKER LAW, P.C.
Woodinville, WA 98072
14 2. Thomas Anderson
(866) 823-8275
Thomas Anderson & Co.
15 P.O. Box 1872
822 Broadway
16 Sonoma, CA 95476
Telephone (707) 938-2146
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3. Neal Bordenave, JD, CPCU, RPLU, ARM, AIC
18 RiskPro Insurance Services, Inc.
61060 Snowberry Place
19 Bend, OR 97702
Telephone: (530) 891-8100
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21 Plaintiff may also call those experts listed by those persons whose depositions have been taken in
22 the within action, and/or those experts listed by any other party in this action. Plaintiff may call
23 those persons for expert opinion testimony at the trial of this matter. Plaintiff reserves the right,
24 pursuant to Sections 2034.210 and 2034.260 of the Code of Civil Procedure, as well as any other
25 constitutional, statutory and/or common law rights they may have, to later name other experts before
26 trial, or call to testify at trial, experts not named whose testimony is needed to aid in the prosecution
27 of the action and/or refute or rebut the contentions and testimony of other parties’ experts.
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PLAINTIFF GARY KOOP’S EXPERT DESIGNATIONS
1 Additional expert witnesses may be retained to testify. If this occurs, their identities will be disclosed
2 immediately pursuant to the procedures set forth in Code of Civil Procedure Section § 2034.280.
3 Plaintiff specifically reserves the right to provide a supplemental list of expert witnesses if he
4 receives any amended scope and cost of repair. Plaintiff further reserves his rights to provide an
5 additional supplemental list of experts upon receipt of the list of other parties’ additional expert
6 witnesses as they are identified.
7 Pursuant to the provisions of Section 2034 of the Code of Civil Procedure, Plaintiff requests that
8 any party desiring to take the deposition of a potential expert witness herein declared, tender a fee,
9 in advance, to said potential expert witness based upon the anticipated length of the deposition, not
10 exceeding said deponent’s customary hourly or daily fee reasonably and necessarily spent in
11 connection with the deposition. It is further understood that should the deposition take longer than
12 originally anticipated; the balance of the fee due shall be paid by the party noticing/requesting the
14241 NE Woodinville-Duvall Road, Suite 382
13 deposition within 5 days of receipt of said deponent’s itemized Statement of Services.
MONAHAN TUCKER LAW, P.C.
Woodinville, WA 98072
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(866) 823-8275
15 DATED: September 28, 2023 MONAHAN TUCKER LAW, P.C.
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By:
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18 Stacy M. Tucker, Esq.
19 Attorneys for Plaintiff,
GARY KOOP
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PLAINTIFF GARY KOOP’S EXPERT DESIGNATIONS
1 DECLARATION OF COUNSEL IN SUPPORT THEREOF
2 I, Stacy Monahan Tucker, declare as follows:
3 1. I am an attorney at law, duly licensed to practice before all Courts in the State of California
4 and a partner of the firm Monahan Tucker Law, P.C., counsel of record for Plaintiff GARY KOOP
5 (hereinafter “Plaintiff”) in this action.
6 2. I am completely familiar with the files, pleadings, and facts in this case and if called upon
7 as a witness, I could and would competently testify to the following facts based upon my own
8 personal knowledge or information and belief.
9 3. The following individuals have been retained to provide expert testimony at the time of
10 trial on behalf of Plaintiff in this action:
11 A. As to Mr. David Bano, I am informed and believe the following is true: Mr. Bano is the
12 former Chief Claims Officer of Nationwide Mutual Insurance Company (“Nationwide”) from 2007
14241 NE Woodinville-Duvall Road, Suite 382
13 to May 2019. He was also the President of Nationwide Indemnity Company, an affiliate of
MONAHAN TUCKER LAW, P.C.
Woodinville, WA 98072
14 Nationwide focused exclusively on property and casualty insurance, and in the course of his career
(866) 823-8275
15 managed all extra-contractual litigation for Nationwide. Earlier in his career he managed agency
16 sales and underwriting in Michigan and in Philadelphia. He is currently the president of Enterprise
17 Associates LLC. If called to testify, Mr. Bano will testify regarding the accepted claim adjustment
18 industry standards and practices in California, the accepted underwriting and reformation standards
19 and practices in California, the accepted reformation practices in California, and how Farmers’ and
20 Mr. Hunsaker’s actions failed to comply with those standards. He will also testify as to Farmers’
21 and Mr. Hunsaker’s willful violations of California insurance code and regulations based on his
22 understanding from his experience in the industry. Mr. Bano will opine on Farmers’ investigation,
23 communications, adjustment, and documentation of Plaintiff’s claim. Mr. Bano has agreed to testify
24 and will be sufficiently familiar with this action to submit to an oral deposition concerning the
25 specific testimony, including any opinion and its basis, that he will provide at trial. Mr. Bano’s
26 hourly fee is $500 for review and $650 for deposition and trial testimony. A true and correct copy
27 of his curriculum vitae is attached as Exhibit 1 and is fully incorporated by reference.
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PLAINTIFF GARY KOOP’S EXPERT DESIGNATIONS
1 B. As to Mr. Thomas Anderson, I am informed and believe the following is true: Mr.
2 Anderson is the owner of Thomas Anderson & Co., a general building contractor, general
3 engineering contractor, and consulting firm. He has been the owner from 1974 to present. He also
4 is the owner and President of Tactical Construction Solutions. Mr. Anderson is a licensed contractor
5 with active A and B contracting licenses in California under license no. 715281. He also maintains
6 an active real estate license in California. If called to testify, Mr. Anderson will testify regarding
7 assessment and evaluation of the construction costs of Plaintiff’s property, the estimated
8 replacement cost, details of planned reconstruction, attributes of the original construction, and
9 rebuilding costs for the dwelling to replace the subject property at issue. His testimony will also
10 address the damages claimed by Plaintiff. Mr. Anderson has agreed, if called, to testify at the trial
11 of this matter and will be sufficiently familiar with the pending action to submit to a meaningful
12 oral deposition concerning any opinion and its basis. Mr. Anderson requests that the estimated time
14241 NE Woodinville-Duvall Road, Suite 382
13 of the any expert witness deposition be determined by noticing attorney and shared with Thomas
MONAHAN TUCKER LAW, P.C.
Woodinville, WA 98072
14 Anderson at least one week prior to testifying. The fee for the estimated time (i.e. check made out
(866) 823-8275
15 to Thomas Anderson & Co.) shall be paid prior to the start of the deposition. A true and correct copy
16 of Mr. Anderson’s curriculum vitae is attached as Exhibit 2 and is fully incorporated by reference.
17 C. As to Mr. Neal Bordenave, I am informed and believe the following is true: Mr.
18 Bordenave is the President and CEO of RiskPro Insurance Services, Inc., a national insurance
19 brokerage firm, and has been so since 1999. He has had an active California property broker-agent
20 license since 1988. If called to testify, Mr. Bordenave will testify on issues relating to property and
21 casualty insurance, including the standard of care for Mr. Hunsaker and his agents relating to
22 allegations of breach of duty asserted by Plaintiff. Mr. Bordenave is also expected to provide expert
23 testimony relating to the damages sustained by Plaintiff in this case. Mr. Bordenave has agreed, if
24 called, to testify at the trial of this matter and will be sufficiently familiar with the pending action to
25 submit to a meaningful oral deposition concerning any opinion and its basis. Mr. Bordenave’s
26 hourly fee is $495 for review. Mr. Bordenave charges a flat rate of $1,980 for up to four hours of
27 deposition and trial testimony, and $495 per hour for any testimony beyond four hours. Mr.
28 Bordenave requests that any travel required for a deposition include reimbursement for lodging, a
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PLAINTIFF GARY KOOP’S EXPERT DESIGNATIONS
1 $100 per day per diem, car rental, and air fare. A true and correct copy of Mr. Bordenave’s
2 curriculum vitae is attached as Exhibit 3 and is fully incorporated by reference.
3 I declare under penalty of perjury that the foregoing is true and correct. Executed this
4 26th day of September 2023, in Woodinville, Washington.
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7 Stacy M. Tucker, Esq.
8 Attorneys for Plaintiff,
GARY KOOP
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14241 NE Woodinville-Duvall Road, Suite 382
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MONAHAN TUCKER LAW, P.C.
Woodinville, WA 98072
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PLAINTIFF GARY KOOP’S EXPERT DESIGNATIONS
EXHIBIT 1
EXHIBIT 1
David A. Bano
Sarasota, FL & Columbus, OH
P: 614.519.5389 E: davebano212@gmail.com
L: linkedin.com/in/dave-bano-33577011/
PROFESSIONAL EXPERIENCE
PROPERTY & CASUALTY EXPERT WITNESS & ADVISOR June 2019 - Present
▪Serving the legal and insurance communities through expert witness opinions.
▪Senior Product Advisor with Scale Artificial Intelligence, San Francisco.
NATIONWIDE INSURANCE, Columbus, OH
Chief Claims Officer – Nationwide Enterprise 2007 – 2019
President & Chief Operations Officer, Nationwide Indemnity Company
▪ Hands-on, highly experienced leader responsible for all of Nationwide’s claims operations, including subsidiaries.
▪ Led 8000+ employee associates and managed a $1.2B annual operating budget.
▪ Supervised senior staff of 9 claims vice presidents.
▪ Directed development of corporate claims policy, claims legal decisions, business strategy and operating processes.
▪ Senior business partner to executive leadership of underwriting, product, general counsel, finance and actuarial.
▪ Provided claims management across all lines of coverage: personal auto & home, commercial, excess & surplus,
asbestos and environmental, agribusiness, private client, national flood, pet/veterinary and special investigation
anti-fraud teams, including all extra-contractual and bad faith claim situations.
▪ Managed all major litigation including 9/11, wildfires, flooding, hurricanes, molestation, mold, sinkholes & drywall.
▪ Developed, with General Counsel support, extra-contractual/bad faith case review and authorization processes.
▪ Applied 35+ years of personal experience and a work-history that began as a multi-line adjuster trainee.
Vice President, Home Office Claims Staff 2004 – 2007
▪ Corporate management of personal lines and commercial claims divisions comprised of 5000+ employees with an
annual operating budget of $800M.
▪ Teamed with senior staff and general counsel to create discipline-specific best practices and performance goals for
each claims section. Led expert teams that developed the actions/activities required to attain these targets, which
successfully drove improvement across loss adjustment expenses, claim costs and the trade combined ratio.
▪ Identified and recruited top talent for multiple elected-officer claims positions. Introduced succession
management, diversity & inclusion teams and claim executive developmental action-planning.
▪ Led national catastrophe teams, managing all forms of environmental disaster response countrywide.
▪ Improved claims severities year over year, delivering industry-best performance in primary injury coverages and all
auto / material damage lines. Achieved similar results in subrogation, salvage/recovery, and loss of use costs.
▪ Responsible for all claims quality control and auditing. Conducted regular Regional operations reviews.
ADDITIONAL RELATED EXPERIENCE
Vice President – Field Claims
Spearheaded field claims operations for company’s largest regional divisions. Oversaw litigation management, claims
quality, customer service, hiring, productivity and employee satisfaction across twenty-one states.
Associate Vice President – New York Claims
Led emergency turnaround of New York claim operations. Directed full scale re-engineering of New York’s claims
processes, organizational structure, litigation strategies and leadership. Direct report to the President of Nationwide.
Regional Vice President, General Manager – Michigan
Managed all Nationwide operations within Michigan. Oversaw statewide P&L and led all sales, claims & underwriting
activities. Directed the most rapid Agency storefront expansion in the history of Nationwide. Grew exclusive agency
force by 65% statewide while tripling direct written premium.
Market Manager – Philadelphia
Directed Agency Sales, Claims and Underwriting operations across Nationwide’s largest urban market.
State Claims Manager – Pennsylvania
Recruited from Allstate to lead Nationwide’s largest field claims operation.
ALLSTATE INSURANCE, New York Operations, Westchester, NY
Market Claims Manager – NY
EDUCATION & PROFESSIONAL DEVELOPMENT
▪ Bachelor of Arts (BA), Binghamton University, New York
▪ The Executive Education Program, Wharton School of Business, University of Pennsylvania, Philadelphia
PROFESSIONAL ASSOCIATIONS & MEMBERSHIPS
▪ Chief Claims Officer Roundtable (CCOR)
▪ Board of Governors – National Insurance Crime Bureau (NICB)
▪ Founding Chair and Director - Pennsylvania Insurance Fraud Authority (IFPA)
▪ Society of Automotive Engineers (SAE)
▪ Partners for Automated Vehicle Education (PAVE)
▪ International Association of Special Investigations Units (IASIU)
▪ International Association of Chiefs of Police (IACP)
▪ Coalition Against Insurance Fraud (CAIF)
EXHIBIT 2
EXHIBIT 2
THOMAS E. ANDERSON
THOMAS ANDERSON & CO.
GENERAL BUILDING CONTRACTORS
GENERAL ENGINEERING CONTRACTORS
REAL ESTATE DEVELOPERS
P.O. Box 1872, 822 Broadway, Sonoma, CA 95476
(707) 938-2146 fax (707) 938-5023
www.tomanderson.com
Tax ID No. 68-0358543
CONSTRUCTION CONSULTING
Thomas Anderson & Co. is a general building contracting, general engineering contracting and construction
consulting firm specializing in industry standards, building envelope performance, site work, transportation
corridors, site safety, preconstruction surveys, real estate development, project administration, risk
management, failure analysis, asbestos, effective management of project completion (CPM), management of
bio-organic growth identification, containment, abatement programs and implementation, real estate
appraisal, arbitration, mediation, trial preparation and testimony.
ARCHITECTURE & PLANNING
Thomas Anderson & Co. offers design and planning services, including new residential and commercial
projects as well as remedial design of repairs to single and multi-family residential buildings, commercial
office and industrial buildings, and tenant improvements. Pioneered sustainable and high-performance design
and construction. Currently, Thomas Anderson & Co. holds a General Building Contractor license and a
General Engineering Contractor license in California.
EXPERIENCE
Thomas Anderson & Co., Owner, 1974 - Present
General Contractor, 1974 – Present
Licensed in California, License Number 300719 (B - General Building Contractor, A – General
Engineering Contractor). Participated in all phases of construction. Completed more than 250 residential,
commercial, industrial, government projects, swimming pools, and infrastructure projects. Subject license
presently nonoperative.
Owner and President, Tactical Construction Solutions, Inc., 1995 - Present
Licensed in California, License Number 715281 (B - General Building Contractor, A – General
Engineering Contractor)
Licensed in Nevada, 2000, License #0050195, B2-Residential & Small Commercial.
Department of Real Estate, State of California, Real Estate License-Sales, 2007 - Present
Licenses in California, Identification Number 01825559
Muni-Mula, LLC, 2010 – 2014
Adaptive re-use of commercial office building; architecture, planning, construction administration,
property management, and civil site work. Commercial use.
Benz-Anderson-Ebbesen, LLC, 2004 - Present
Adaptive re-use of commercial office building; architecture, planning, construction administration,
property management, and civil site work. Commercial use. Lease holder.
Patri-Anderson, LLC - Design Build Partnership, 1997 - Present
Architecture, planning, construction administration, property management. Commercial and residential
uses. Leasehold improvements. Lease holder.
THOMAS E. ANDERSON, cont.
Anderson Berger Rouse 2003 - 2008
Architecture, property management; commercial lease hold improvements. Commercial use.
Hillcrest Investments, 2001 - 2008
Architecture, planning, construction administration, residential housing use.
Anderson-Patri-Rouse, LLC – Design Build Partnership, 2000 – 2006
Architecture, planning, construction administration, property management. Commercial and residential
uses. Leasehold improvements. Lease holder.
Principal Partner, Remedial Repair Specialties, 1994 - 1999
Licensed in California, License #687587, General Building Contractor. Specializing in remedial repair of
single family dwellings, attached residential housing, and commercial office buildings. Installation of
tenant improvements. Providing remedial construction services to the industry throughout California.
Clay McCullough & Co., Inc., 1983 - 1988
Field inspections, insurance inspections, reviewing legal documents, preparing cost estimates,
depositions, arbitrations, court testimony. Approved as an expert witness by the State Attorney General.
Owner and President, Ruraltown, Inc., 1978 - 1983
Licensed in California, License #427561, Class B, General Building Contractor.
Superintendent of Construction and Development for Views Land Co., Walter L. Benson, 1971 - 1983
Local 35 Carpenters Union, 1973
Journeyman carpenter, foreman, superintendent.
Worked as journeyman carpenter for:
Valentine Corporation, Journeyman, Concrete Specialty, transportation, marine, commercial and industrial
projects.
Colin Hess Construction Company, Foreman; residential and commercial construction.
Robert Flournoy Construction Company, Foreman, framing, residential construction.
Morton Construction Company, Foreman, residential and commercial construction.
Plantech Inc., Charles Miltner, Foreman, residential and commercial construction.
Superintendent of Construction for Western Gold Development Corp., Lamont Langworthy, AIA, 1972
Hunters Point Bay Naval Shipyard, San Francisco, CA, 1968
Shipfitter Shop Eleven, submarines, Aircraft Carrier Midway, CV 41.
EDUCATION
Sonoma State University, Uniform Building Code, 2010
Sonoma State University, Construction Project Management, 2009
First Tuesday Continuing Education, Legal Aspects of Real Estate, 2009
First Tuesday Continuing Education, Real Estate Practices, 2009
Kaplan-Anthony Schools, California Real Estate Principles, 2007
Construction Schedule Analysis and Evaluation of Delay Damages, San Jose State University Continuing
Education, San Jose, CA, 1997
Sonoma State University, B.A., 1971. Emphasis in design, engineering and construction of monumental
sculpture, color and design, architectural history.
PRESENTATIONS
Guest Lecturer, John F. Kennedy School of Law, 1999
Building Component & Construction Symposium II, sponsored by Thomas Anderson & Co., Sonoma, CA,
March 13, 1998
Page 2 of 4 January 1, 2023
THOMAS E. ANDERSON, cont.
Building Component & Construction Symposium I, sponsored by Thomas Anderson & Co., Sonoma, CA,
November 7, 1997
Panelist, "Construction Defects," Assoc. of Defense Counsel, March 22, 1996, San Jose, CA, March, 1996
Speaker, "Risk Management, Target on Your Back," National Association of Remodeling Industry (NARI),
Sonoma, CA, 1994
Speaker, "Roofing in the 90's," California Institute of Associations EXPO '92, Oakland, CA, 1992
Speaker, "Component Reserve Studies," Community Associations Institute, North Bay Seminar, 1992
Panelist, "Roof Maintenance and Repair," California Institute of Associations EXPO '91, Oakland, CA, 1991
PROFESSIONAL AFFILIATIONS
American Society of Professional Estimators, Inc.
Build It Green Professional
LEED AP – Leadership in Energy and Environmental Design, Accredited Professional
California State Guard, Warrant Officer, Office of Emergency Services, Office of the Adjutant General,
Retired
Construction Specifications Institute (CSI)
International Code Council
International Conference of Building Officials (ICBO)
League of California Cities
National Roofing Contractors Association (NRCA)
North Bay Association of Realtors (NORBAR)
North Coast Builders Exchange
Redwood Empire Remodelers Association
Scaffold Industry Association (SIA)
Sonoma Green Business, Economic Development Partnership, Chamber of Commerce, Sonoma, CA
Water Environment Federation
Western Construction Consultants Association (WESTCON, founding member)
SEMINARS AND WORKSHOPS
Disclosure-Risk Management, Robert Brand, Santa Rosa, CA, January, 2010
Real Estate Risk Management, NORBAR, Sonoma, CA, July, 2009
Construction Specifications Institute, Fire Resistive Construction, San Francisco, CA, March, 2004
Construction Specifications Institute, Vegetated Roof Assemblies, San Francisco, CA, March, 2004
2004 Planners Institute, League of California Cities, Monterey, CA, March, 2004
Legal and Ethical Issues for
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1 Stacy M. Tucker (SBN 218942) smtucker@mtlawpc.com 2 MONAHAN TUCKER LAW, PC 14241 NE Woodinville-Duvall Road 3 Suite 382 4 Woodinville, WA 98072 T: (206) 486-3553 5 F: (206) 339-7155 6 Lisa S. Kantor (SBN 110678) lkantor@kantorlaw.net 7 KANTOR & KANTOR, LLP 19839 Nordhoff Street 8 Northridge, CA 91324 T: (818) 886-2525 9 F: (818) 350-6272 10 Attorneys for Plaintiff, Gary Koop 11 SUPERIOR COURT OF THE STATE OF CALIFORNIA 14241 NE Woodinville-Duvall Road, Suite 382 12 COUNTY OF SONOMA MONAHAN TUCKER LAW, P.C. 13 Woodinville, WA 98072 (866) 823-8275 14 Case No.: SCV-266944 15 GARY KOOP, [Assigned for All Purposes to the Plaintiff, Honorable Jane Gaskell] 16 v. 17 DECLARATION OF STACY TUCKER FIRE INSURANCE EXCHANGE, dba IN SUPPORT OF PLAINTIFF’S 18 FARMERS INSURANCE GROUP; BRIAN MOTION TO AUGMENT EXPERT 19 HUNSAKER, DISCLOSURES Defendants. 20 Date: Time: 21 Dept: 7 22 23 Action Filed: August 24, 2020 Trial Date: March 29, 2024 24 25 26 27 28 1 DECLARATION OF STACY TUCKER 1 I, Stacy Tucker, declare as follows: 2 1. I am an attorney at law duly licensed to practice before all courts in the State of 3 California and am a partner at the law firm of Monahan Tucker Law, P.C., attorneys for Plaintiff, 4 Gary Koop. I make this Declaration on behalf of Plaintiff Gary Koop in relation to his Motion for 5 Summary Adjudication in this action. I have personal knowledge of the facts stated herein and, if 6 called upon to testify, could and would competently testify thereto. 7 2. Plaintiff Gary Koop bases the calculation of his breach of contract damages on the 8 delta between the value of the insurance coverage calculated by 360Value for his Property when 9 listed as “above average” quality grade and when listed as “premium” quality grade. The parties 10 have conducted discovery on this issue and met and conferred, and all parties agree that there is no 11 way in 360Value to determine what the exact amount of coverage would have been for his Property 14241 NE Woodinville-Duvall Road, Suite 382 12 as “premium” quality grade in 2017, because 360Value updates it databases in real time. MONAHAN TUCKER LAW, P.C. 13 3. Plaintiff timely provided his expert disclosures on September 28, 2023. A true and Woodinville, WA 98072 (866) 823-8275 14 correct copy of those disclosures is attached as Exhibit 1. 15 4. In January 2022 and March 2023, I went to the Farmers website at 16 https://www.farmers.com/ to determine what the coverage would be for Plaintiff’s Property when 17 calculated at the “above average” quality grade and then at “premium” quality grade. I took screen 18 shots of each page created in running both scenarios. In Plaintiff’s oppositions to the motions for 19 summary judgment filed by each defendant, I relied on the 2022 screenshots to demonstrate 20 Plaintiff’s contract damages. In Plaintiff’s motions for summary judgment against each Defendant, 21 I relied on the 2023 screenshots to demonstrate Plaintiff’s contract damages. These declarations and 22 screenshots are attached to the Request For Judicial Notice filed with Plaintiff’s Motion and this 23 Declaration. 24 5. When I prepared Plaintiff’s expert disclosures in September 2023, I intended to have 25 Brian Hunsaker, on the witness stand, use a laptop connected to the Court’s larger screen to access 26 the Farmers website in front of the jury, and run those scenarios in real time to demonstrate and 27 authenticate the two scenarios and their difference. For that reason, I did not designate an expert to 28 opine as to the difference in coverage between the two quality grades. 2 DECLARATION OF STACY TUCKER 1 6. On November 3, 2023, the parties filed a joint stipulation asking the Court to 2 postpone the November 17, 2023 trial date while a new judge was assigned and the pending motions 3 for summary judgment were ruled upon. That stipulation agreed to tie the deadline for taking expert 4 depositions to the new trial date to be assigned by the Court. 5 7. On or about November 6, 2023, I went to https://www.farmers.com/ again to run 6 updated scenarios. I learned at that time that at some point between March 2023 and November 6, 7 2023, Farmers disabled the ability for California homeowners to obtain quotes on their residences. 8 Other states can still obtain an automatic quote, but entering a California results in instructions to 9 contact a Farmers agent to obtain a homeowners insurance quote. I therefore was no longer able to 10 proceed with my prior plan to ask Brian Hunsaker to run scenarios on the stand in order to 11 authenticate the scenarios. 14241 NE Woodinville-Duvall Road, Suite 382 12 8. On November 7, 2023, I contacted Kevin Hromas, an insurance appraiser who had MONAHAN TUCKER LAW, P.C. 13 been previously recommended to me as a potential expert for this subject. He agreed to serve as an Woodinville, WA 98072 (866) 823-8275 14 expert. 15 9. On November 12, 2023, I prepared Plaintiff’s proposed augmented expert 16 disclosures. A true and correct copy of these proposed disclosures is attached as Exhibit 2. 17 10. On November 12, 2023, I served Plaintiff’s proposed augmented expert disclosures 18 on all parties and asked to meet and confer about whether they would stipulate to the inclusion of 19 Mr. Hromas, or if Plaintiff would need to file a motion to augment. A true and correct copy of that 20 email is attached as Exhibit 3. 21 11. On November 13, 2023, counsel for Farmers responded with a letter declining to 22 stipulate and providing Farmers’ basis for its refusal. Counsel for Hunsaker has not responded to 23 Plaintiff’s proposed augmented disclosures. A true and correct copy of the November 13, 2023 letter 24 I received from Farmers’ counsel Steven Inouye is attached as Exhibit 3. 25 12. No expert depositions have been taken in this matter and none are currently 26 scheduled. 27 /// 28 /// 3 DECLARATION OF STACY TUCKER 1 I declare under penalty of perjury that the foregoing is true and correct and that this 2 Declaration was executed on November 17, 2023, at Woodinville, Washington. 3 4 _______________________________ Stacy M. Tucker 5 6 7 8 9 10 11 14241 NE Woodinville-Duvall Road, Suite 382 12 MONAHAN TUCKER LAW, P.C. 13 Woodinville, WA 98072 (866) 823-8275 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 4 DECLARATION OF STACY TUCKER EXHIBIT 1 EXHIBIT 1 1 Stacy M. Tucker (SBN 218942) smtucker@mtlawpc.com 2 MONAHAN TUCKER LAW, PC 14241 NE Woodinville-Duvall Road 3 Suite 382 4 Woodinville, WA 98072 T: (206) 486-3553 5 F: (206) 339-7155 6 Glenn R. Kantor (SBN 122643) gkantor@kantorlaw.net 7 KANTOR & KANTOR, LLP 19839 Nordhoff Street 8 Northridge, CA 91324 T: (818) 886-2525 9 F: (818) 350-6272 10 Attorneys for Plaintiff Gary Koop 11 SUPERIOR COURT OF THE STATE OF CALIFORNIA 12 14241 NE Woodinville-Duvall Road, Suite 382 COUNTY OF SONOMA 13 MONAHAN TUCKER LAW, P.C. Woodinville, WA 98072 14 GARY KOOP, Case No.: SCV-266944 (866) 823-8275 Plaintiff, [Honorable Oscar Pardo – Dept. 19] 15 v. 16 PLAINTIFF GARY KOOP’S DESIGNATION OF EXPERT FIRE INSURANCE EXCHANGE, dba 17 WITNESSES PURSUANT TO C.C.P. FARMERS INSURANCE GROUP; BRIAN §2034.260; DECLARATION OF 18 HUNSAKER, COUNSEL IN SUPPORT THEREOF Defendants. 19 20 21 22 23 24 Action Filed: August 24, 2020 25 Trial Date: November 17, 2023 26 27 28 1 PLAINTIFF GARY KOOP’S EXPERT DESIGNATIONS 1 TO ALL PARTIES AND TO THEIR COUNSEL OF RECORD: 2 PLEASE TAKE NOTICE that Plaintiff Gary Koop (hereinafter “Plaintiff”) hereby submits the 3 following list of witnesses whom he intends to call as experts at the time of trial. This designation 4 of expert trial witnesses is made pursuant to Code of Civil Procedure Section 2034.210 et seq. This 5 designation is made with the express reservation of all rights under Section 2034.210 et seq., 6 including the right to amend or supplement this designation as may be necessary. 7 Defendant may call the following experts pursuant to the Code of Civil Procedure Section 2034.260 8 for the purpose of forming and expressing an opinion: 9 10 I. EXPERT WITNESSES 11 1. David Bano AES Consulting Group, Inc. 12 626 Avenida de Mayo 14241 NE Woodinville-Duvall Road, Suite 382 Sarasota, FL 34242 13 Telephone (614) 519.5389 MONAHAN TUCKER LAW, P.C. Woodinville, WA 98072 14 2. Thomas Anderson (866) 823-8275 Thomas Anderson & Co. 15 P.O. Box 1872 822 Broadway 16 Sonoma, CA 95476 Telephone (707) 938-2146 17 3. Neal Bordenave, JD, CPCU, RPLU, ARM, AIC 18 RiskPro Insurance Services, Inc. 61060 Snowberry Place 19 Bend, OR 97702 Telephone: (530) 891-8100 20 21 Plaintiff may also call those experts listed by those persons whose depositions have been taken in 22 the within action, and/or those experts listed by any other party in this action. Plaintiff may call 23 those persons for expert opinion testimony at the trial of this matter. Plaintiff reserves the right, 24 pursuant to Sections 2034.210 and 2034.260 of the Code of Civil Procedure, as well as any other 25 constitutional, statutory and/or common law rights they may have, to later name other experts before 26 trial, or call to testify at trial, experts not named whose testimony is needed to aid in the prosecution 27 of the action and/or refute or rebut the contentions and testimony of other parties’ experts. 28 2 PLAINTIFF GARY KOOP’S EXPERT DESIGNATIONS 1 Additional expert witnesses may be retained to testify. If this occurs, their identities will be disclosed 2 immediately pursuant to the procedures set forth in Code of Civil Procedure Section § 2034.280. 3 Plaintiff specifically reserves the right to provide a supplemental list of expert witnesses if he 4 receives any amended scope and cost of repair. Plaintiff further reserves his rights to provide an 5 additional supplemental list of experts upon receipt of the list of other parties’ additional expert 6 witnesses as they are identified. 7 Pursuant to the provisions of Section 2034 of the Code of Civil Procedure, Plaintiff requests that 8 any party desiring to take the deposition of a potential expert witness herein declared, tender a fee, 9 in advance, to said potential expert witness based upon the anticipated length of the deposition, not 10 exceeding said deponent’s customary hourly or daily fee reasonably and necessarily spent in 11 connection with the deposition. It is further understood that should the deposition take longer than 12 originally anticipated; the balance of the fee due shall be paid by the party noticing/requesting the 14241 NE Woodinville-Duvall Road, Suite 382 13 deposition within 5 days of receipt of said deponent’s itemized Statement of Services. MONAHAN TUCKER LAW, P.C. Woodinville, WA 98072 14 (866) 823-8275 15 DATED: September 28, 2023 MONAHAN TUCKER LAW, P.C. 16 By: 17 18 Stacy M. Tucker, Esq. 19 Attorneys for Plaintiff, GARY KOOP 20 21 22 23 24 25 26 27 28 3 PLAINTIFF GARY KOOP’S EXPERT DESIGNATIONS 1 DECLARATION OF COUNSEL IN SUPPORT THEREOF 2 I, Stacy Monahan Tucker, declare as follows: 3 1. I am an attorney at law, duly licensed to practice before all Courts in the State of California 4 and a partner of the firm Monahan Tucker Law, P.C., counsel of record for Plaintiff GARY KOOP 5 (hereinafter “Plaintiff”) in this action. 6 2. I am completely familiar with the files, pleadings, and facts in this case and if called upon 7 as a witness, I could and would competently testify to the following facts based upon my own 8 personal knowledge or information and belief. 9 3. The following individuals have been retained to provide expert testimony at the time of 10 trial on behalf of Plaintiff in this action: 11 A. As to Mr. David Bano, I am informed and believe the following is true: Mr. Bano is the 12 former Chief Claims Officer of Nationwide Mutual Insurance Company (“Nationwide”) from 2007 14241 NE Woodinville-Duvall Road, Suite 382 13 to May 2019. He was also the President of Nationwide Indemnity Company, an affiliate of MONAHAN TUCKER LAW, P.C. Woodinville, WA 98072 14 Nationwide focused exclusively on property and casualty insurance, and in the course of his career (866) 823-8275 15 managed all extra-contractual litigation for Nationwide. Earlier in his career he managed agency 16 sales and underwriting in Michigan and in Philadelphia. He is currently the president of Enterprise 17 Associates LLC. If called to testify, Mr. Bano will testify regarding the accepted claim adjustment 18 industry standards and practices in California, the accepted underwriting and reformation standards 19 and practices in California, the accepted reformation practices in California, and how Farmers’ and 20 Mr. Hunsaker’s actions failed to comply with those standards. He will also testify as to Farmers’ 21 and Mr. Hunsaker’s willful violations of California insurance code and regulations based on his 22 understanding from his experience in the industry. Mr. Bano will opine on Farmers’ investigation, 23 communications, adjustment, and documentation of Plaintiff’s claim. Mr. Bano has agreed to testify 24 and will be sufficiently familiar with this action to submit to an oral deposition concerning the 25 specific testimony, including any opinion and its basis, that he will provide at trial. Mr. Bano’s 26 hourly fee is $500 for review and $650 for deposition and trial testimony. A true and correct copy 27 of his curriculum vitae is attached as Exhibit 1 and is fully incorporated by reference. 28 4 PLAINTIFF GARY KOOP’S EXPERT DESIGNATIONS 1 B. As to Mr. Thomas Anderson, I am informed and believe the following is true: Mr. 2 Anderson is the owner of Thomas Anderson & Co., a general building contractor, general 3 engineering contractor, and consulting firm. He has been the owner from 1974 to present. He also 4 is the owner and President of Tactical Construction Solutions. Mr. Anderson is a licensed contractor 5 with active A and B contracting licenses in California under license no. 715281. He also maintains 6 an active real estate license in California. If called to testify, Mr. Anderson will testify regarding 7 assessment and evaluation of the construction costs of Plaintiff’s property, the estimated 8 replacement cost, details of planned reconstruction, attributes of the original construction, and 9 rebuilding costs for the dwelling to replace the subject property at issue. His testimony will also 10 address the damages claimed by Plaintiff. Mr. Anderson has agreed, if called, to testify at the trial 11 of this matter and will be sufficiently familiar with the pending action to submit to a meaningful 12 oral deposition concerning any opinion and its basis. Mr. Anderson requests that the estimated time 14241 NE Woodinville-Duvall Road, Suite 382 13 of the any expert witness deposition be determined by noticing attorney and shared with Thomas MONAHAN TUCKER LAW, P.C. Woodinville, WA 98072 14 Anderson at least one week prior to testifying. The fee for the estimated time (i.e. check made out (866) 823-8275 15 to Thomas Anderson & Co.) shall be paid prior to the start of the deposition. A true and correct copy 16 of Mr. Anderson’s curriculum vitae is attached as Exhibit 2 and is fully incorporated by reference. 17 C. As to Mr. Neal Bordenave, I am informed and believe the following is true: Mr. 18 Bordenave is the President and CEO of RiskPro Insurance Services, Inc., a national insurance 19 brokerage firm, and has been so since 1999. He has had an active California property broker-agent 20 license since 1988. If called to testify, Mr. Bordenave will testify on issues relating to property and 21 casualty insurance, including the standard of care for Mr. Hunsaker and his agents relating to 22 allegations of breach of duty asserted by Plaintiff. Mr. Bordenave is also expected to provide expert 23 testimony relating to the damages sustained by Plaintiff in this case. Mr. Bordenave has agreed, if 24 called, to testify at the trial of this matter and will be sufficiently familiar with the pending action to 25 submit to a meaningful oral deposition concerning any opinion and its basis. Mr. Bordenave’s 26 hourly fee is $495 for review. Mr. Bordenave charges a flat rate of $1,980 for up to four hours of 27 deposition and trial testimony, and $495 per hour for any testimony beyond four hours. Mr. 28 Bordenave requests that any travel required for a deposition include reimbursement for lodging, a 5 PLAINTIFF GARY KOOP’S EXPERT DESIGNATIONS 1 $100 per day per diem, car rental, and air fare. A true and correct copy of Mr. Bordenave’s 2 curriculum vitae is attached as Exhibit 3 and is fully incorporated by reference. 3 I declare under penalty of perjury that the foregoing is true and correct. Executed this 4 26th day of September 2023, in Woodinville, Washington. 5 6 7 Stacy M. Tucker, Esq. 8 Attorneys for Plaintiff, GARY KOOP 9 10 11 12 14241 NE Woodinville-Duvall Road, Suite 382 13 MONAHAN TUCKER LAW, P.C. Woodinville, WA 98072 14 (866) 823-8275 15 16 17 18 19 20 21 22 23 24 25 26 27 28 6 PLAINTIFF GARY KOOP’S EXPERT DESIGNATIONS EXHIBIT 1 EXHIBIT 1 David A. Bano Sarasota, FL & Columbus, OH P: 614.519.5389 E: davebano212@gmail.com L: linkedin.com/in/dave-bano-33577011/ PROFESSIONAL EXPERIENCE PROPERTY & CASUALTY EXPERT WITNESS & ADVISOR June 2019 - Present ▪Serving the legal and insurance communities through expert witness opinions. ▪Senior Product Advisor with Scale Artificial Intelligence, San Francisco. NATIONWIDE INSURANCE, Columbus, OH Chief Claims Officer – Nationwide Enterprise 2007 – 2019 President & Chief Operations Officer, Nationwide Indemnity Company ▪ Hands-on, highly experienced leader responsible for all of Nationwide’s claims operations, including subsidiaries. ▪ Led 8000+ employee associates and managed a $1.2B annual operating budget. ▪ Supervised senior staff of 9 claims vice presidents. ▪ Directed development of corporate claims policy, claims legal decisions, business strategy and operating processes. ▪ Senior business partner to executive leadership of underwriting, product, general counsel, finance and actuarial. ▪ Provided claims management across all lines of coverage: personal auto & home, commercial, excess & surplus, asbestos and environmental, agribusiness, private client, national flood, pet/veterinary and special investigation anti-fraud teams, including all extra-contractual and bad faith claim situations. ▪ Managed all major litigation including 9/11, wildfires, flooding, hurricanes, molestation, mold, sinkholes & drywall. ▪ Developed, with General Counsel support, extra-contractual/bad faith case review and authorization processes. ▪ Applied 35+ years of personal experience and a work-history that began as a multi-line adjuster trainee. Vice President, Home Office Claims Staff 2004 – 2007 ▪ Corporate management of personal lines and commercial claims divisions comprised of 5000+ employees with an annual operating budget of $800M. ▪ Teamed with senior staff and general counsel to create discipline-specific best practices and performance goals for each claims section. Led expert teams that developed the actions/activities required to attain these targets, which successfully drove improvement across loss adjustment expenses, claim costs and the trade combined ratio. ▪ Identified and recruited top talent for multiple elected-officer claims positions. Introduced succession management, diversity & inclusion teams and claim executive developmental action-planning. ▪ Led national catastrophe teams, managing all forms of environmental disaster response countrywide. ▪ Improved claims severities year over year, delivering industry-best performance in primary injury coverages and all auto / material damage lines. Achieved similar results in subrogation, salvage/recovery, and loss of use costs. ▪ Responsible for all claims quality control and auditing. Conducted regular Regional operations reviews. ADDITIONAL RELATED EXPERIENCE Vice President – Field Claims Spearheaded field claims operations for company’s largest regional divisions. Oversaw litigation management, claims quality, customer service, hiring, productivity and employee satisfaction across twenty-one states. Associate Vice President – New York Claims Led emergency turnaround of New York claim operations. Directed full scale re-engineering of New York’s claims processes, organizational structure, litigation strategies and leadership. Direct report to the President of Nationwide. Regional Vice President, General Manager – Michigan Managed all Nationwide operations within Michigan. Oversaw statewide P&L and led all sales, claims & underwriting activities. Directed the most rapid Agency storefront expansion in the history of Nationwide. Grew exclusive agency force by 65% statewide while tripling direct written premium. Market Manager – Philadelphia Directed Agency Sales, Claims and Underwriting operations across Nationwide’s largest urban market. State Claims Manager – Pennsylvania Recruited from Allstate to lead Nationwide’s largest field claims operation. ALLSTATE INSURANCE, New York Operations, Westchester, NY Market Claims Manager – NY EDUCATION & PROFESSIONAL DEVELOPMENT ▪ Bachelor of Arts (BA), Binghamton University, New York ▪ The Executive Education Program, Wharton School of Business, University of Pennsylvania, Philadelphia PROFESSIONAL ASSOCIATIONS & MEMBERSHIPS ▪ Chief Claims Officer Roundtable (CCOR) ▪ Board of Governors – National Insurance Crime Bureau (NICB) ▪ Founding Chair and Director - Pennsylvania Insurance Fraud Authority (IFPA) ▪ Society of Automotive Engineers (SAE) ▪ Partners for Automated Vehicle Education (PAVE) ▪ International Association of Special Investigations Units (IASIU) ▪ International Association of Chiefs of Police (IACP) ▪ Coalition Against Insurance Fraud (CAIF) EXHIBIT 2 EXHIBIT 2 THOMAS E. ANDERSON THOMAS ANDERSON & CO. GENERAL BUILDING CONTRACTORS GENERAL ENGINEERING CONTRACTORS REAL ESTATE DEVELOPERS P.O. Box 1872, 822 Broadway, Sonoma, CA 95476 (707) 938-2146 fax (707) 938-5023 www.tomanderson.com Tax ID No. 68-0358543 CONSTRUCTION CONSULTING Thomas Anderson & Co. is a general building contracting, general engineering contracting and construction consulting firm specializing in industry standards, building envelope performance, site work, transportation corridors, site safety, preconstruction surveys, real estate development, project administration, risk management, failure analysis, asbestos, effective management of project completion (CPM), management of bio-organic growth identification, containment, abatement programs and implementation, real estate appraisal, arbitration, mediation, trial preparation and testimony. ARCHITECTURE & PLANNING Thomas Anderson & Co. offers design and planning services, including new residential and commercial projects as well as remedial design of repairs to single and multi-family residential buildings, commercial office and industrial buildings, and tenant improvements. Pioneered sustainable and high-performance design and construction. Currently, Thomas Anderson & Co. holds a General Building Contractor license and a General Engineering Contractor license in California. EXPERIENCE Thomas Anderson & Co., Owner, 1974 - Present General Contractor, 1974 – Present Licensed in California, License Number 300719 (B - General Building Contractor, A – General Engineering Contractor). Participated in all phases of construction. Completed more than 250 residential, commercial, industrial, government projects, swimming pools, and infrastructure projects. Subject license presently nonoperative. Owner and President, Tactical Construction Solutions, Inc., 1995 - Present Licensed in California, License Number 715281 (B - General Building Contractor, A – General Engineering Contractor) Licensed in Nevada, 2000, License #0050195, B2-Residential & Small Commercial. Department of Real Estate, State of California, Real Estate License-Sales, 2007 - Present Licenses in California, Identification Number 01825559 Muni-Mula, LLC, 2010 – 2014 Adaptive re-use of commercial office building; architecture, planning, construction administration, property management, and civil site work. Commercial use. Benz-Anderson-Ebbesen, LLC, 2004 - Present Adaptive re-use of commercial office building; architecture, planning, construction administration, property management, and civil site work. Commercial use. Lease holder. Patri-Anderson, LLC - Design Build Partnership, 1997 - Present Architecture, planning, construction administration, property management. Commercial and residential uses. Leasehold improvements. Lease holder. THOMAS E. ANDERSON, cont. Anderson Berger Rouse 2003 - 2008 Architecture, property management; commercial lease hold improvements. Commercial use. Hillcrest Investments, 2001 - 2008 Architecture, planning, construction administration, residential housing use. Anderson-Patri-Rouse, LLC – Design Build Partnership, 2000 – 2006 Architecture, planning, construction administration, property management. Commercial and residential uses. Leasehold improvements. Lease holder. Principal Partner, Remedial Repair Specialties, 1994 - 1999 Licensed in California, License #687587, General Building Contractor. Specializing in remedial repair of single family dwellings, attached residential housing, and commercial office buildings. Installation of tenant improvements. Providing remedial construction services to the industry throughout California. Clay McCullough & Co., Inc., 1983 - 1988 Field inspections, insurance inspections, reviewing legal documents, preparing cost estimates, depositions, arbitrations, court testimony. Approved as an expert witness by the State Attorney General. Owner and President, Ruraltown, Inc., 1978 - 1983 Licensed in California, License #427561, Class B, General Building Contractor. Superintendent of Construction and Development for Views Land Co., Walter L. Benson, 1971 - 1983 Local 35 Carpenters Union, 1973 Journeyman carpenter, foreman, superintendent. Worked as journeyman carpenter for: Valentine Corporation, Journeyman, Concrete Specialty, transportation, marine, commercial and industrial projects. Colin Hess Construction Company, Foreman; residential and commercial construction. Robert Flournoy Construction Company, Foreman, framing, residential construction. Morton Construction Company, Foreman, residential and commercial construction. Plantech Inc., Charles Miltner, Foreman, residential and commercial construction. Superintendent of Construction for Western Gold Development Corp., Lamont Langworthy, AIA, 1972 Hunters Point Bay Naval Shipyard, San Francisco, CA, 1968 Shipfitter Shop Eleven, submarines, Aircraft Carrier Midway, CV 41. EDUCATION Sonoma State University, Uniform Building Code, 2010 Sonoma State University, Construction Project Management, 2009 First Tuesday Continuing Education, Legal Aspects of Real Estate, 2009 First Tuesday Continuing Education, Real Estate Practices, 2009 Kaplan-Anthony Schools, California Real Estate Principles, 2007 Construction Schedule Analysis and Evaluation of Delay Damages, San Jose State University Continuing Education, San Jose, CA, 1997 Sonoma State University, B.A., 1971. Emphasis in design, engineering and construction of monumental sculpture, color and design, architectural history. PRESENTATIONS Guest Lecturer, John F. Kennedy School of Law, 1999 Building Component & Construction Symposium II, sponsored by Thomas Anderson & Co., Sonoma, CA, March 13, 1998 Page 2 of 4 January 1, 2023 THOMAS E. ANDERSON, cont. Building Component & Construction Symposium I, sponsored by Thomas Anderson & Co., Sonoma, CA, November 7, 1997 Panelist, "Construction Defects," Assoc. of Defense Counsel, March 22, 1996, San Jose, CA, March, 1996 Speaker, "Risk Management, Target on Your Back," National Association of Remodeling Industry (NARI), Sonoma, CA, 1994 Speaker, "Roofing in the 90's," California Institute of Associations EXPO '92, Oakland, CA, 1992 Speaker, "Component Reserve Studies," Community Associations Institute, North Bay Seminar, 1992 Panelist, "Roof Maintenance and Repair," California Institute of Associations EXPO '91, Oakland, CA, 1991 PROFESSIONAL AFFILIATIONS American Society of Professional Estimators, Inc. Build It Green Professional LEED AP – Leadership in Energy and Environmental Design, Accredited Professional California State Guard, Warrant Officer, Office of Emergency Services, Office of the Adjutant General, Retired Construction Specifications Institute (CSI) International Code Council International Conference of Building Officials (ICBO) League of California Cities National Roofing Contractors Association (NRCA) North Bay Association of Realtors (NORBAR) North Coast Builders Exchange Redwood Empire Remodelers Association Scaffold Industry Association (SIA) Sonoma Green Business, Economic Development Partnership, Chamber of Commerce, Sonoma, CA Water Environment Federation Western Construction Consultants Association (WESTCON, founding member) SEMINARS AND WORKSHOPS Disclosure-Risk Management, Robert Brand, Santa Rosa, CA, January, 2010 Real Estate Risk Management, NORBAR, Sonoma, CA, July, 2009 Construction Specifications Institute, Fire Resistive Construction, San Francisco, CA, March, 2004 Construction Specifications Institute, Vegetated Roof Assemblies, San Francisco, CA, March, 2004 2004 Planners Institute, League of California Cities, Monterey, CA, March, 2004 Legal and Ethical Issues for