opposition to State Farm's motion for partial summary judgment

Q. What are they?A. I remember the McIntosh claim.See Exhibit “C” Depo. of K. Rigsby in McIntosh, p. 123:24 - 124:17. Ms. Rigsby furthertestified that there were a number of instances where an engineer, sent by State Farm, reviewedthe loss with the policyholder at the home and told them what their opinion of the loss was andthen, inexplicably, the final report would show up several weeks later with a completely differentconclusion. See Id. at p. 129-130. It became clear later in the deposition that the reason for thechange in reports was that Lecky King was sending the engineering reports back to be rewrittenbecause she didn’t like the conclusions reached by the engineering company. (“There was a largestack [of engineering reports] on Lecky’s desk, and she said all of them had to go back.”) Id. at p.137-138. When asked why the reports had to be sent back, Ms. Rigsby relayed that Ms. Kingwas adamant that the engineering reports were too favorable to policyholders.Id. at p. 139. 3Q. Okay. Did you inquire of her when she made that commentabout any of the reasons, if any, that may have existed as tothe reasons the engineering reports were going back?A. She said that – her comment was that they [the engineers] –they all must be related to the policyholders.Q. That’s what Lecky King said?A. Uh-huh, and that’s why they needed to go back.3Ms. Rigsby testified that the stack of engineering reports on Lecky’s desk that had to goback were about 2 feet high. Id. at p. 158-159. (Note that the average engineering report is 3-4pages.)-6-