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FRANCIS X. DOHERTY (52329)
— J. EDWARD KERLEY (175695)
DOROTHY F. WALDRUP (237900)
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MARGARET ADEYAN, EMMANUEL Case No.: RG06278260
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Case No. RG06278260 DECLARATION OF J.EDWARD KERLEY
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of benefits has been ratified at the direction of Allstate’s CEO, Thomas J. Wilson.
Plaintiffs respectfully request that the Court reconsider its decision regarding punitive
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damages on the separate and distinct ground that Allstate has ratified the withholding of
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3. Thomas J. Wilson, 49, is the president and chief executive officer of The
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of Mr. Wilson’s bio as published on www.allstate.com. .
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4. Kathie Pardi is the senior staff claim representative of Allstate Insurance
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withhold policy benefits. Ms. Adeyan wrote to Allstate because they have a continuing °
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26, 2007. Attached as Exhibit E is a true and correct copy of Ms. Pardi’s letter of June
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Case No. RG06278260 DECLARATION OF J.EDWARD KERLEY
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7. I only received notice that my firm had received Ms. Pardi’s letters on July
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Case No. RG06278260 DECLARATION OF J.EDWARD KERLEY
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AllstateNewsroom -Senior Management Tey: - Thomas J. Wilson Grecia atte com categories/26/reteasesi4044
Allstate - You're in good hands
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Thomas J. Wilson
President and Chief Executive Officer
The Allstate Corporation
Thomas J.Wilson, 49, is the president and chief executive officer of The Allstate Corporation and Allstate
Insurance Company. Wilson is also a member of The Allstate Corporation board of directors.
From 2005 to 2006, Wilson was president and chief operating officer of The Allstate Corporation, and from
2002 to 2006 he was also president of Allstate Protection.
From 1999 to 2002, Wilson was chairman and president of Allstate Financial. From 1995 to 1998, Wilson
served as Allstate's chief financial officer. He joined Allstate in 1995 from Sears, Roebuck and Co., where he
was vice president of strategy and analysis.
Prior to Sears, he was managing director of mergers and acquisitions at Dean Witter Reynolds from 1986 to
1993. He has also held various financial positions at Amoco Corporation, where he worked from 1980 to
1986.
Wilson is aboard member of Rush University Medical Center, Francis W. Parker School and the Property
Casualty Insurers Association of America. He isalso amember of the Young Presidents Organization, the
Financial Services Forum and The Business Roundtable.
A native of St.Clair Shores, Michigan; Wilson holds aMaster of Management degree from Northwestern
University's J.L. Kellogg Graduate School of Management and a Bachelor of Science degree in Business
Administration from the University of Michigan.
e-mail this page
exaiBit
1 of 1 7/15/2007 11:05 PM
SUPERIOR COURT OF THE STATE OF CALIFORNIA
COUNTY OF ALAMEDA ~
~--000---
MARGARET ADEYAN, EMMANUEL )
ADEYAN, )
)
Plaintiffs, )
‘) No. RG 06278260
vs. ).
ALLSTATE INSURANCE COMPANY, a ) CERT PieD
corporation; MARZOHF BROTHERS ) _—s
CONSTRUCTION, INC., and DOES 1 ) CO q
through 20, inclusive, ;
. Defendants.
Deposition of
KATHIE PARDI
Friday, March 30, 2007
=
‘Reported by:
GEORGE SCHUMER, CSR 3326 (393506)
a EXHIBIT
MERRILL LEGAL SOLUTION §$
575 Market Street, 11th Floor . 415.357.4300
www.inerrilicorp.com/law San Francisco, CA 94105
KATHIE PARDI vac 30, 2007
10: 09 :23 any military service?
10: 09 224 A. No.
10: 09: 24 Q. Are you presently employed?
10: 09 :29 A. Yes.
10 709: 29 Q. By whom?
10: 09: 30 A. Allstate.
10: 09: 31 Q. Where is your office?
10: 09: 34 A. In Roseville, California.
10: o9 :38 Q. What is your current title?
10: O9: 44 10 A. I believe it is senior staff claim
10: 09 248 1i representative.
10: 09: 56° ‘12 Q. How. long have you been a senior staff claim
10: 10: OL 13 representative?
10: 10: 02 14 A. I'm not sure. About 15 years.
10: 10: 13 15 Q. Would you describe your duties as a senior
10: 10: 17 16 staff claim representative?
10 10: 19 17 MR. WILLIAMS: At present?
10: 10: 22 18 MR. DOHERTY: Yes. Why don't we start at
10: 10: 25 19 present? |
10: 10 726 20 THE WITNESS: At present I am an inside
10: 10 :29 21 structure adjuster.
10: 10 235 22 MR. DOHERTY: Q. “can you explain what an
10: 10 336 23 inside structure adjuster does?
10: 10 :39 24 A. Claims that come through, that require
_10: 10: 42 25 investigation, or are simple estimates -- we put
10
MERRILL LEGAL SOLUTIONS
(800) 869-9132
June 15, 2007
Thomas Wilson
President
Allstate .
2775 Sanders Road, Suite F
Northbrook, IL 60062 ,
Dear Mr. Wilson,
|am a mother of three children (Cameron 9, Emerald 6 and Autumn 4), and
married to Emmanuel Adeyan who works at Kaiser Permanente as aRN. Our home
was insured by Allstate and a fire severely damaged our home in 2005.
|am writing to ask you to use your power to stop the terrible ordeal that your.
company is putting us through. One of your employees has apologized for her
behavior, but your company has done nothing to fixthe harm they caused by stopping
payment of our living expenses. My family was forced to use our savings while we were
always afraid that we would end up homeless. Allstate even came in and took my
children’s beds and our furniture, leaving us to sleep on the floor, with no chairs to sit in,
or table to eat from. No one at Allstate has said that they did anything wrong. We have
lived with this stress for two years now and have not been able to replace all of our
belongings, repair our home, or get back our savings. What hurts even more, is that on
top of allof this, Allstate has blamed us for everything.
To prove that itwas not our fault, | am sending transcripts of your employee's
depositions so you know what happened. |am also sending copies of this letter to
Catherine Brune, Vice President ofAllstate, George Ruebenson, President of Allstate
Protection, Joan Walker, Senior Vice President of Corporate Relations, and Michael
McCabe, Vice President of Allstate, so they know, too. :
For more than a year now, the company has blamed us. Your company’s
attorneys, the Sonnenschein firm, have put us to unbelievable expense. Please letme
know that you got this letter and ifAllstate willstop this war against us. Allstate has our
home number and you can call me or my husband at anytime to discuss this. |hope
you do call and put a stop to this.
Mers ~Y Ad rd bam
EXHIBIT (__
June 26, 2007
Margaret Adeyan
796 Minerva Street
Hayward, CA 94544
RE: ClaimNo.: © 6593620302
Insured: Adeyan
Date of Loss: 03/13/2005
Dear Mrs. Adeyan: ©
As you will recall,J was one of the Allstate adjusterswho worked on your homeowners
insurance claim following the March 13, 2005 fireatyour home. As one of the adjusters who
was familiarwith your claim when itwas pending, I have been asked to respond to your letterof
June 15,2007 addressed to our home office,
As you are aware, your claim to Allstatewas investigated, adjusted, paid and closed more than a
year ago. After your claim was paid and the filewas closed, you fileda lawsuit against Allstate
over itshandling of your claim. Both sides arerepresented by attorneys in that case. Your claim
itselfisno longer pending. Because your June 15 letteridentifiesno issues thatare still
outstanding from the March 13, 2005 fire loss,I am unsure exactly what itisthat you believe
Allstate should be doing with respect to your closed claim. Although you request that Allstate
“put a stop tothis,” the only pending matter between you and Allstate isyour lawsuit. Since you
filedthe suit,only you, not Allstate,can put a stop toit.
That said, Allstate iscommitted topromptly providing itscustomers with allbenefits afforded by
theirpolicies. Therefore, if you willidentify any outstanding aspects of your claim that you
believe have never been resolved adequately, I willbe happy tolook intothose issues and
respond toyou as quickly as time permits. Icannot, of course, contro! the outcome of your
lawsuit, since thematter isin litigationand must be resolved by the court.
Should you believe Allstatehas wrongfully denied your claim, inwhole or in part,you may have
itsposition reviewed by theCalifornia Department of Insurance by calling 1-800-927-HELP or
by writing to the Claims Service Bureau, Department of Insurance, 300 South Spring Street,Los
Angeles, CA 90013.
I look forward tohearing from you.
Sincerely,
Lae
Allstate Insurance
hace
Company
ce: Francis X. Doherty, Esq. (by fax and mail) |
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( ‘d 9705 ‘ON 0926082 FL¥iST1y rita £000 ‘92‘Nar
Northern California Property MCO
Allstate Insurance
P.O. Box 1109 ,
Roseville, CA 95678-9938
June 27, 2007
Pe)
Margaret Adeyan ¥ Lae EP
796 Minerva Street Jy yi wy S
Hayward, CA 94544 . ~
: 23 2u7 (0)
_ RE: ClaimNo.: 6593620302
Insured: Adeyan
Date of Loss: 03/13/2005
. Dear Mrs. Adeyan: —_ we et 7: _— “
As you will recall, I was one of the Allstate adjusters who worked on your homeowners
insurance claim following the March 13, 2005 fireat your home. As one of the adjusters
who was familiar with your claim when itwas pending, I have been asked to respond toto
your letterof June 15, 2007 addressed to our home office.
As you are aware, your claim to Allstate was investigated, adjusted, paid and closed more
than a year ago. After your claim was paid and the file was closed, you filed a lawsuit
against Allstate over itshandling of your claim. Both sides are represented by attorneys in
that case. Your claim itself isno longer pending. Because your June 15 letter identifies no
issues that are stilloutstanding from the March 13, 2005 fire loss, Iam unsure exactly what
itis that you believe Allstate should be doing with respect to your closed claim. Although
you request that Allstate “put a stop to this,” the only pending matter between you and
Allstate isyour lawsuit. Since you filed the suit, only you, not Allstate, can put a stop to it.
That said, Allstate is committed to promptly providing its customers with allbenefits
afforded by their policies. Therefore, if you will identify any outstanding aspects of your
claim that you believe have never been resolved adequately, Iwill be happy to look into
those issues and respond to you as-quickly as time permits. I cannot, of course, control the
outcome of your lawsuit, since the matter is in litigation and must be resolved by the court.
Should you believe Allstate has wrongfully denied your claim, in whole or in part, you may
have itsposition reviewed by the California Department of Insurance by calling 1-800-927-
HELP or by writing to the Claims Service Bureau, Department of Insurance, 300 South
Spring Street, Los Angeles, CA 90013.
Ilook forward to hearingfrom you.
Sincerely,
Kathie M. Pardi
Allstate Property-Casualty Claim Service Organization
exuiBit
Preview
e — @ mma FRANCIS X. DOHERTY (52329) — J. EDWARD KERLEY (175695) DOROTHY F. WALDRUP (237900) bo DOHERTY GEORGESON KERLEY LLP 999 Fifth Avenue, Suite 400 FILED WwW San Rafael, CA 94901 N 1) 453-2300 ALAMEDA COUNTY bh 415) 455-0270 Facsimile gy ae abe 7UU/ ws ATTORNEYS Margaret Adeyan, FOREmmanuel PLAINTIFES Adeyan CLERK py CA OF THE CZ. SUPERIOR -— GOURT : = ON eputy ~ SUPERIOR COURT OF CALIFORNIA © COUNTY OF ALAMEDA — UNLIMITED JURISDICTION Oo MARGARET ADEYAN, EMMANUEL Case No.: RG06278260 SCS —_ ADEYAN, DECLARATION OF J. EDWARD YF — a — Plaintiffs, KERLEY IN SUPPORT OF MOTION — . . FOR RECONSIDERATION NY — ~ 2 ise] V. 4 r=} + = Date: . WD v, 25S — n- Zz nv + a 2 Smn ALLSTATE INSURANCE COMPANY, a) Time: eS io) < corporation; MARZOLF BROTHERS Department: Pe “A 3 e) o _ 5 = isa) uo ~ oO Ww + ~~ CONSTRUCTION, INC., and DOES 1 4 < through 20, inclusive, AW io) = al —_ ae 3 +z oO ay = ss 2 a n Defendants. DR a — 4 rN = B HN — 1. I am one of the attorneys of record for Plaintiffs Emmanuel and Margaret CO _— Adeyan. OO 2. | On or about May 9, 2007, Allstate filed a motion for summary Judgment, or CO NO in the alternative summary adjudication as to Plaintiffs’ claims for breach of contract, bad KF bo faith and punitive damages. NY No 3. On July 11, 2007, the Honorable Frank Roesch, Judge of this Court, issued WO bo an order granting Allstate’s motion for summary adjudication on the grounds that BB bo Plaintiffs presented insufficient evidence that managing agents of Allstate withheld MN NO benefits. | ON bo 4. This motion is brought based on newly acquired evidence obtained from NO oN Allstate. The new evidence demonstrates on another ground that Allstate’s withholding No 1 Case No. RG06278260 DECLARATION OF J.EDWARD KERLEY YS of benefits has been ratified at the direction of Allstate’s CEO, Thomas J. Wilson. Plaintiffs respectfully request that the Court reconsider its decision regarding punitive YN damages on the separate and distinct ground that Allstate has ratified the withholding of WY benefits from the Adeyans. | | FB 3. Thomas J. Wilson, 49, is the president and chief executive officer of The WH Allstate Corporation and Allstate Insurance Company. Wilson is also a member of The DA Allstate Corporation board of directors. Attached as Exhibit A isa true and correct copy NY of Mr. Wilson’s bio as published on www.allstate.com. . oO 4. Kathie Pardi is the senior staff claim representative of Allstate Insurance 0 and has been for 15 years. Attached as Exhibit B is a true and correct copy of page 10 of © Kathie Pardi’s deposition of March 30, 2007, confirming her title and number of years in | LLP that position for Allstate. | No KERLEY 400 5. Plaintiff Margaret Adeyan wrote to Thomas Wilson, Allstate’s CEO, on es) 94901 Suite 453-2300 June 15, 2007. Ms. Adeyan requested payment of the outstanding living expenses owed GEORGESON CA — Avenue, Rafael, under the policy of insurance. Ms. Adeyan wrote to the CEO when she learned Allstate (415) WN Fifth San contended that no managing agent had ratified Allstate’s decision to terminate to DOHERTY nN 999 withhold policy benefits. Ms. Adeyan wrote to Allstate because they have a continuing ° ~~ obligation to investigate and pay benefits that are owed under a policy, even when Co litigation ispending. Attached as Exhibit C is a true and correct copy of Ms. Adeyan’s oO letter. @©CO 6. Kathleen Pardi wrote twice in response to the June 15 letter to Allstate’s —_m- CEO. Ms. Pardi represented that she was responding to the letter on behalf of Allstate’s to CEO. Allstate’s position isthat her file is closed and no additional benefits are owed. wo Ms. Pardi’s letters show that Allstate continues to ratify the withholding of benefits. +> According to Allstate, Ms. Adeyan may only obtain her policy benefits through action by MN this Court. Attached as Exhibit D is a true and correct copy of Ms. Pardi’s letter of June NHN 26, 2007. Attached as Exhibit E is a true and correct copy of Ms. Pardi’s letter of June nN 27, 2007. oOo Case No. RG06278260 DECLARATION OF J.EDWARD KERLEY e | @ 7. I only received notice that my firm had received Ms. Pardi’s letters on July — 10, 2007.. The letters were received by our office on June 26 and 29, 2007. I prepared N and presented a declaration and the above letters for the Court’s hearing on Allstate’s WwW motion for summary judgment on July 11, 2007. The Court understandably indicated that itwould decline to consider the newly obtained evidence at the hearing. The Court WN did indicate that itwould consider newly obtained information upon a motion for N reconsideration. ~~ I declare under penalty of perjury under the laws of the State of California that the oo foregoing istrue and correct. Executed on July 17, 2006, at San Clemente, California. - SO he eee LLP J. Edward Kerley \ KERLEY 400 OES 94901 Suite 453-2300 GEORGESON CA Avenue, FOE Rafael, (415) Fifth San DOHERTY 999 FF KF KH NO NY NY WN NY NO NHN po NNO Case No. RG06278260 DECLARATION OF J.EDWARD KERLEY SEES :*SIIW= ee AllstateNewsroom -Senior Management Tey: - Thomas J. Wilson Grecia atte com categories/26/reteasesi4044 Allstate - You're in good hands Search Newsroom, ccseed + enc Thomas J. Wilson President and Chief Executive Officer The Allstate Corporation Thomas J.Wilson, 49, is the president and chief executive officer of The Allstate Corporation and Allstate Insurance Company. Wilson is also a member of The Allstate Corporation board of directors. From 2005 to 2006, Wilson was president and chief operating officer of The Allstate Corporation, and from 2002 to 2006 he was also president of Allstate Protection. From 1999 to 2002, Wilson was chairman and president of Allstate Financial. From 1995 to 1998, Wilson served as Allstate's chief financial officer. He joined Allstate in 1995 from Sears, Roebuck and Co., where he was vice president of strategy and analysis. Prior to Sears, he was managing director of mergers and acquisitions at Dean Witter Reynolds from 1986 to 1993. He has also held various financial positions at Amoco Corporation, where he worked from 1980 to 1986. Wilson is aboard member of Rush University Medical Center, Francis W. Parker School and the Property Casualty Insurers Association of America. He isalso amember of the Young Presidents Organization, the Financial Services Forum and The Business Roundtable. A native of St.Clair Shores, Michigan; Wilson holds aMaster of Management degree from Northwestern University's J.L. Kellogg Graduate School of Management and a Bachelor of Science degree in Business Administration from the University of Michigan. e-mail this page exaiBit 1 of 1 7/15/2007 11:05 PM SUPERIOR COURT OF THE STATE OF CALIFORNIA COUNTY OF ALAMEDA ~ ~--000--- MARGARET ADEYAN, EMMANUEL ) ADEYAN, ) ) Plaintiffs, ) ‘) No. RG 06278260 vs. ). ALLSTATE INSURANCE COMPANY, a ) CERT PieD corporation; MARZOHF BROTHERS ) _—s CONSTRUCTION, INC., and DOES 1 ) CO q through 20, inclusive, ; . Defendants. Deposition of KATHIE PARDI Friday, March 30, 2007 = ‘Reported by: GEORGE SCHUMER, CSR 3326 (393506) a EXHIBIT MERRILL LEGAL SOLUTION §$ 575 Market Street, 11th Floor . 415.357.4300 www.inerrilicorp.com/law San Francisco, CA 94105 KATHIE PARDI vac 30, 2007 10: 09 :23 any military service? 10: 09 224 A. No. 10: 09: 24 Q. Are you presently employed? 10: 09 :29 A. Yes. 10 709: 29 Q. By whom? 10: 09: 30 A. Allstate. 10: 09: 31 Q. Where is your office? 10: 09: 34 A. In Roseville, California. 10: o9 :38 Q. What is your current title? 10: O9: 44 10 A. I believe it is senior staff claim 10: 09 248 1i representative. 10: 09: 56° ‘12 Q. How. long have you been a senior staff claim 10: 10: OL 13 representative? 10: 10: 02 14 A. I'm not sure. About 15 years. 10: 10: 13 15 Q. Would you describe your duties as a senior 10: 10: 17 16 staff claim representative? 10 10: 19 17 MR. WILLIAMS: At present? 10: 10: 22 18 MR. DOHERTY: Yes. Why don't we start at 10: 10: 25 19 present? | 10: 10 726 20 THE WITNESS: At present I am an inside 10: 10 :29 21 structure adjuster. 10: 10 235 22 MR. DOHERTY: Q. “can you explain what an 10: 10 336 23 inside structure adjuster does? 10: 10 :39 24 A. Claims that come through, that require _10: 10: 42 25 investigation, or are simple estimates -- we put 10 MERRILL LEGAL SOLUTIONS (800) 869-9132 June 15, 2007 Thomas Wilson President Allstate . 2775 Sanders Road, Suite F Northbrook, IL 60062 , Dear Mr. Wilson, |am a mother of three children (Cameron 9, Emerald 6 and Autumn 4), and married to Emmanuel Adeyan who works at Kaiser Permanente as aRN. Our home was insured by Allstate and a fire severely damaged our home in 2005. |am writing to ask you to use your power to stop the terrible ordeal that your. company is putting us through. One of your employees has apologized for her behavior, but your company has done nothing to fixthe harm they caused by stopping payment of our living expenses. My family was forced to use our savings while we were always afraid that we would end up homeless. Allstate even came in and took my children’s beds and our furniture, leaving us to sleep on the floor, with no chairs to sit in, or table to eat from. No one at Allstate has said that they did anything wrong. We have lived with this stress for two years now and have not been able to replace all of our belongings, repair our home, or get back our savings. What hurts even more, is that on top of allof this, Allstate has blamed us for everything. To prove that itwas not our fault, | am sending transcripts of your employee's depositions so you know what happened. |am also sending copies of this letter to Catherine Brune, Vice President ofAllstate, George Ruebenson, President of Allstate Protection, Joan Walker, Senior Vice President of Corporate Relations, and Michael McCabe, Vice President of Allstate, so they know, too. : For more than a year now, the company has blamed us. Your company’s attorneys, the Sonnenschein firm, have put us to unbelievable expense. Please letme know that you got this letter and ifAllstate willstop this war against us. Allstate has our home number and you can call me or my husband at anytime to discuss this. |hope you do call and put a stop to this. Mers ~Y Ad rd bam EXHIBIT (__ June 26, 2007 Margaret Adeyan 796 Minerva Street Hayward, CA 94544 RE: ClaimNo.: © 6593620302 Insured: Adeyan Date of Loss: 03/13/2005 Dear Mrs. Adeyan: © As you will recall,J was one of the Allstate adjusterswho worked on your homeowners insurance claim following the March 13, 2005 fireatyour home. As one of the adjusters who was familiarwith your claim when itwas pending, I have been asked to respond to your letterof June 15,2007 addressed to our home office, As you are aware, your claim to Allstatewas investigated, adjusted, paid and closed more than a year ago. After your claim was paid and the filewas closed, you fileda lawsuit against Allstate over itshandling of your claim. Both sides arerepresented by attorneys in that case. Your claim itselfisno longer pending. Because your June 15 letteridentifiesno issues thatare still outstanding from the March 13, 2005 fire loss,I am unsure exactly what itisthat you believe Allstate should be doing with respect to your closed claim. Although you request that Allstate “put a stop tothis,” the only pending matter between you and Allstate isyour lawsuit. Since you filedthe suit,only you, not Allstate,can put a stop toit. That said, Allstate iscommitted topromptly providing itscustomers with allbenefits afforded by theirpolicies. Therefore, if you willidentify any outstanding aspects of your claim that you believe have never been resolved adequately, I willbe happy tolook intothose issues and respond toyou as quickly as time permits. Icannot, of course, contro! the outcome of your lawsuit, since thematter isin litigationand must be resolved by the court. Should you believe Allstatehas wrongfully denied your claim, inwhole or in part,you may have itsposition reviewed by theCalifornia Department of Insurance by calling 1-800-927-HELP or by writing to the Claims Service Bureau, Department of Insurance, 300 South Spring Street,Los Angeles, CA 90013. I look forward tohearing from you. Sincerely, Lae Allstate Insurance hace Company ce: Francis X. Doherty, Esq. (by fax and mail) | exuipit \> ( ‘d 9705 ‘ON 0926082 FL¥iST1y rita £000 ‘92‘Nar Northern California Property MCO Allstate Insurance P.O. Box 1109 , Roseville, CA 95678-9938 June 27, 2007 Pe) Margaret Adeyan ¥ Lae EP 796 Minerva Street Jy yi wy S Hayward, CA 94544 . ~ : 23 2u7 (0) _ RE: ClaimNo.: 6593620302 Insured: Adeyan Date of Loss: 03/13/2005 . Dear Mrs. Adeyan: —_ we et 7: _— “ As you will recall, I was one of the Allstate adjusters who worked on your homeowners insurance claim following the March 13, 2005 fireat your home. As one of the adjusters who was familiar with your claim when itwas pending, I have been asked to respond toto your letterof June 15, 2007 addressed to our home office. As you are aware, your claim to Allstate was investigated, adjusted, paid and closed more than a year ago. After your claim was paid and the file was closed, you filed a lawsuit against Allstate over itshandling of your claim. Both sides are represented by attorneys in that case. Your claim itself isno longer pending. Because your June 15 letter identifies no issues that are stilloutstanding from the March 13, 2005 fire loss, Iam unsure exactly what itis that you believe Allstate should be doing with respect to your closed claim. Although you request that Allstate “put a stop to this,” the only pending matter between you and Allstate isyour lawsuit. Since you filed the suit, only you, not Allstate, can put a stop to it. That said, Allstate is committed to promptly providing its customers with allbenefits afforded by their policies. Therefore, if you will identify any outstanding aspects of your claim that you believe have never been resolved adequately, Iwill be happy to look into those issues and respond to you as-quickly as time permits. I cannot, of course, control the outcome of your lawsuit, since the matter is in litigation and must be resolved by the court. Should you believe Allstate has wrongfully denied your claim, in whole or in part, you may have itsposition reviewed by the California Department of Insurance by calling 1-800-927- HELP or by writing to the Claims Service Bureau, Department of Insurance, 300 South Spring Street, Los Angeles, CA 90013. Ilook forward to hearingfrom you. Sincerely, Kathie M. Pardi Allstate Property-Casualty Claim Service Organization exuiBit