opposition to State Farm's motion for partial summary judgment

• Ms. Rigsby admitted that State Farm defrauded the McIntoshes. (“When I foundthe report [the first report with the sticky note on it] I considered it to be State Farm defraudedthem. But the fact that I did not call them, I participated in that.”) Id. at p. 264:17 - 265:13.• Ms. Rigsby testified that State Farm trained their adjusters to call everything waterdamage and not wind damage. Id. at p. 265.p. 373.• Ms. Rigsby emphasized that the concealment of the first report was wrong. Id. at• Ms. Rigsby testified that State Farm began shredding documents after subpoenasfrom government officials started to issue.Id. at p. 425-426.Q. Subsequent to the serving of the grand jurysubpoena, were documents from [the State Farmcatastrophe office] shredded?A. Yes. . . . and then we got to this location in Biloxiand the subpoenas were – coming out, all of asudden, we started seeing shredder trucks often, Ihad been on CAT [catastrophe duty] for 8 years andI don’t know that I have ever seen a shredder truckat the office, I knew we shredded, but I don’t knowwhat, why they would need one so often all of asudden.• Also, State Farm’s lawyer argument that Ms. Rigsby stole the original October12 th Forensic Engineering report, and that is why State Farm did not give it to the McIntoshes,was flatly rebuked by Ms. Rigsby (and no witness has refuted that testimony).Q. And your testimony under oath is that you didn’ttake it, right?A. I took a copy of it. I made a copy and put it back.-8-