Pamela Torres EXHIBITS No. 2 08-02-2017 Madison David Cawthorn - V - Auto-Owners - Insurance - Company PDF

Case 6:16-cv-02240-JA-GJK Document 56-2 Filed 11/09/17 Page 1 of 178 PageID 1679
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Prayers for Madison 2014

April 22, 2014 ■ ©
They going to do a cat scan on Madison's abdomen to

make sure everything is ok there. He's not
comfortable and in a lot of pain but this afternoon
they should put in the tracheostomy tube so pray for
all of that.
If you want to send mail to Madison they changed his

room so now his address is;
Madison Cawthorn
303 N Clyde Morris Blvd.
France Tower 3 North #1331
Daytona Beach, Florida 32114
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Evelyn Parker
I still wake up thinking and praying for

you, Madiison. Praying that your inner
strength will continue to allow you to keep
your focus on the Lord and all that He has
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April 23, 2014 • 0
1 meant to post this last night but it 1 posted it in the

wrong place.
Madison's hemoglobin numbers were down today so

they searched for a source of internal bleeding and
they found that the bleeding was coming from his
pelvis but it had stopped so that is good. They had to
give him more blood and postponed his tracheostomy
until tomorrow morning. Once that tube is in he will be
a lot more comfortable because he won't have the
ventilator down his throat and will be able to be
weened off of his sedation. Thank you all again for
your prayers!!
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Diana Scott Reimink
Lifting Maddison and you all up in prayer.

Praying for Brad and his family.
April 23, 2014 ■ Like • Reply • O 2
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Iffl Prayers for Madison 2014

fiiH April 23, 2014 . 0
Madison had a restful night last night. His numbers

are all looking good. This morning they are going to
drain some fluid they found in his left lung, put in the
tracheostomy tube at 9 and then do dialysis sometime
this afternoon. Once that's finished they should start
waking him up and hopefully they won't have to
sedate him many more times.
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Beverly Stoney
Crossing our fingers, saying prayers, and

holding you all in my heart.
April 23, 2014 • Like • Reply •Q2
Sandra Walsh
May God's healing hand be on Madison

today and always.
April 23, 2014 • Like • Reply
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April 24, 2014
Great day so far! Madison is awake and smiling, he is

breathing on his own right now with the ventilator as
backup, the tracheostomy tube is so much better
because nothing is in his mouth now. His kidneys are
improving, but he needs to be off of dialysis before he
goes to rehab in Atlanta so pray for that. He starting
to be fed by a feeding tube today and may be able to
swallow in the next 2-3 days. This afternoon they
want to put a back brace on him and have him sit in a
special chair. God is great! Thank you all!
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Judy Wall Eiiiot
Dear Madison and Brad, God has

preserved your lives. You will be an
unstoppable team used by God and for
His glory, wait and see. God will use what
Satan tried to destroy, to be a powerful
witness. God knew Maddy had been
h\/ tha onpmw hut
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^ Prayers for Madison 2014

Apri! 25, 2014 ■ 0
Madison's fever is still high today and his white blood

count is higher today too. He will be able to sit in the
chair again today so that will be nice.
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Michelle Stone
Praying that his fever breaks soon. Glad

he gets to look at the world sitting up for
awhile!
Dwayne Priest
Praying Madison..hang in there buddy
Jill Marie Bodenheimer
Continued prayers!
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April 25, 2014 ■ ©
Madison had a long day with dialysis, sitting up for

two hours, and breathing on his own for 50 minutes.
He did not like any of it and is very tired and becoming
discouraged. Please pray for his kidneys over the
weekend because they are doing a trial over the
weekend to see if they can start working on their own.
In addition to praying for complete healing of his body,
please pray for mental endurance and peace.
We would also like have a prayer tomorrow night and

Sunday night to get him through the next week! Thank
you guys, we love you, and Madison is so thankful for
all of your prayers and support!
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Amy Hykin
Dear Lord please give Madison strength

and carry him through each moment.
Please heal his body and use this for your
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April 27, 2014 . ©
Madison just had his first taste of food in 24 days! He

had a little applesauce so he was very happy about
that. He's resting now because he didn't sleep much
last night but we were able to read him your prayers
last night and he was very thankful.
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Robin Outz
Yahoo! Go Team Madison! ....wonderful

news!!! God is good! P.U.S.H....
Pray
Until
Something
Happens
CCT? we will continue to lift you up in

prayers...
SEE TRANSLATION
fo'] Write a comment..

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||||W] Prayers for Madison 2014
wbaBM May 1, 2014 • @
Today marks one month since Madison & Brad's
accident and fittingly it falls on the National Day of
Prayer. Madison is doing very well today and
improving by the hour. This is a true testament to "the
Lord's healing and renewing power" through prayer.
They reduced the size of his tracheostomy tube and

are able to cap it off so that he can speak today when
he has the strength. Breathing and coughing is a
struggle. His kidney gets better every day and they
have not had to do dialysis since Monday!
Today requests are for his kidney, spine, breathing,

pain management and, of course, 100% recovery.
Thank you for your continued prayers!
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992
Rosemary Cawthorn Strickland
Healing day by day, step by step. Prayer
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rHITll1 for Madison 2014 v

j^lll May 4, 2014 • 8
Madison is in a lot of pain, when he has the strength
he is able to speak by capping off his tracheostomy
tube. We heard him pray yesterday and he thanked
God for saving his life and he knew it was God's plan
but he wish he didn't have to hurt all over.
Pray for his pain management, peace of mind, and the

complete healing of his spinal nerves. They plan on
flying Madison to Shepard's in Atlanta at the end of
the week.
P.S. We love all of the pictures you all are sending in!
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Virginia Lawlor
I don't know Madison, I live in Sarasota

Florida and my daughter continue to pray
Madison. The students in my youth group
pray for Madison. On Tuesday nights 150
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Q 140 4 Comments 1 Share
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J Prayers for Madison 2014

jgijy May 5, 2014 • @
We showed Madison this page and he was so happy
to see all of the people supporting him! He told me to
tell you all thank you so much for the prayers and he
loves all of you!
Madison got his last chest tube out which is

awesome! But he is still in a lot of pain and we need to
start praying for for his bowels to start working
regularly and well. Also pray that the expenses for his
travel are worked outiby the insurance. He will be
flown to Atlanta at the end of the week.
o 722 44 Comments 47 Shares
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11111)1 Prayers for Madison 2014

treiy May 5, 2014 - 0
These precious girls have raised over $500 for the
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^ Prayers for Madison 2014
May 6, 2014 • ©
Madison is doing well today! He is totally tube free!

And his bowels have started working. They still need
sofne work so that he can feel whats going on so pray
for that. He will be flown to Atlanta on Thursday. He
has been talking and happy and is starting to be very
much himself, which is so awesome. He is still very
weak though so continue to pray for his strength and
endurance and continued healing!!
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K4ay 7, 2014 • ©
Our last day here at Halifax is bittersweet, we are

super happy that Madison is well enough to head to
rehab but we are all sad that we have to leave all of
these wonderful people at this hospital. Gary Harris,
the owner of the Chick-Fil-A is providing food for ali of
the staff here tomorrow morning as a thank you to
them from Madison.
We also want to thank Daytona First Baptist Church

and the many others who have prayed, supported us
and fed us here in Daytona.
Madison leaves for Shepard's tomorrow morning so

pray for safe travel and for God to continue to show
His mercy to Madison and provide him with the best
care possible while at Shepard's.
The new address for encouraging mail to Madison will

be:
David Madison Cawthorn
Shepard's Rehab
2020 Peachtree Road
NW Atlanta Ga. 30309
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riil¥l 1 Madison 2014

May 9, 2014 • ©
God is so good! Madison was very discouraged this

morning and one of the staff came in to meet him
gave Madison some very encouraging words that
really lifted his spirits, the man was really big and
loves to workout and loves the Lord so it was the
perfect person for Madison to hear from.
Madison will have a big day today and will get to sit up
for a little while and go and meet other kids his age
that are here.
Please pray that God continues to reveal himself to

Madison and provide him with hope and strength so
that he remains his wonderful happy self!
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872
Rosemary Cawthorn Strickiand
YESi! GISDlll
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11 Prayers for Madison 2014

I i| May 10, 2014 • @
Madison is doing a little better, they had him in a chair

yesterday and some clothes on his body, which was
nice to see. Getting him in and out of the bad was
extremely painful for him so he's in bed rest for the
weekend. He is also running a pretty high fever today
so we still need lots of prayers. It has been a very
difficult last couple of days.
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©439
Rosemary Cavvthorn Strickland
Will never stop praying; never.
May 10, 2014 ■ Like • Reply • O6
Judy Wall Elliott
Dear Father God, Come to Madison, give

him rest and comfort, strengthen his body
and resolve in preparation for next week's
difficult hours of rehab. Speak to him in
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ilfij Prayers for Madison 2014

1^ May 14, 2014 • ©
Obviously, we did not send out any graduation
invitations but Madison will be recognized at the
graduation ceremony at Biltmore Baptist this Friday at
7:00. Madison will be Skyped into the ceremony so if
you could make it over there Maddy would really
appreciate the support!
Prayers for this week are for improved bladder

function. God has already healed his kidney now we
this is just a matter of prayer. Thank you all!!!
Here's Madison's mailing address:

Shepherd's Rehab
Room # 425
2020 Peachtree Road
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Laura Mathis Wiilingham
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n Prayers for Madison 2014

May 16, 2014
ConGRADulations Madison!! We got to watch his

ceremony via Skype and it was so great! He really
wishes that he could have been there and says thank
you for all of your prayers! Shepherds also put on a
little graduation ceremony for him and his girlfriend
Gracelyn!
HDavidMadisonCawdiom-son fRogerandPrisc lJaCawthomisa

DAVID MADISON CAWTHORN
weU-mannered, well-spoken, passionate leader who loves the Lord
and has never met a stranger. Always homescbooled active in
youth at Biltmore B^tist Church, Madison is a dedicated athlete
leading Asheville Saints Football as team captain,and playing baseball
and basketball for Asheville Trai]bIazcrs..Hc has competed four years
in NCFCA Debate, selected for Henderson County Junior Leaders
program, and elected President at iGovem East in Washington,DX.
Madison has worked at Chick-fil-A since ha was 14, traveled
extensively and worked three mission weeks in Guatemala.He enjoys
hunting, military strategy and the gym. Madison has b^n nominated to the U. S. Naval
Academy and awarded a full Marine ROTC scholarship to NO Stale University where he will
study Political Science. After serving as an oGIcer in the United Slates Marine Corps,
Madison would like to be a member ofCongress.
Critically injured in an automobile accident April 3, 2014

We can malte ourplans but Vie Lord determines our steps."Proverbs 16:9
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passes Obamacare repeal
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Cawthorn part of
graduation tonight
SPECIAL TO THE CITIZEN-TIMES

rAWTwnDM _ An n-ncs
citizen-times.com
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Ngrtm
Cawthorn is an Asheville Saints football player

and Asheville Trailblazers basketball player
who was vacationing when he was seriously
injured more than a month ago in Florida.
Since the accident, Cawthorn has undergone

multiple surgeries to repair his injuries,
including a broken vertebrae, pelvis and
ankles, as well as a damaged spine.
Cawthorn was nominated to attend the U.S.

Naval Academy by congressman Mark
Meadows in December,
Mail to Cawthorn can be sent to the following

address;
Shepherds Rehab
2020 Peachtree Road

CAWTHORN - AO 01369
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May 17, 2014 - 0
CiTIZEN-TIMES.COM
Cawthorn part of graduation tonight
Through the wonders of technology, Madison Cawth,
See more articles from Asheville Citizen-

Times High School Huddle
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AyTs Owf.EH liu. in:.«iUfU(j t.oH!|!Sfiv

Hom5-S'.vfie:i Ifivuraiire Ccitipanv
fJ'.C!!£rJ tjiiy;E(ice CuiiOOIt!' ,
^%/luto-Otvners Insurance
nyt«.-Tv-Oir'trv Injurpnit Cffiipon? Lift Hon'i'i C-3r BusifiC^St
LmiJisai-Cwfif.;.? ;nrircinc Cosnpat? IrJlAVi
P.O. Rtiv 3200

Ocala, Ft 3447S
PHONE (352)873-9388
ToU Free(800)437 6164
FAX (352)873-9370
May 27. 201^
Roger and Priscilla Cawthoni

On beliair of David Madison Cawihoni
59 Co%cred Bridge Drive
Flat Rock. NC 2873]
Re; Our Insured Bob Ledford's RV 8i, Marine

Clainiant David Madison Cauthom
Our File Number 56-00723-14
Dale of Accident 04 06 14
Dear Mr. and Mrs. Ca^vt}ô^v
'Hiis letter shall serv e to follow up our letter of-April 17,2014.
First, let me say that I am pleased your son Is making progress in his recovery and hope he
continues to do so. I have seen the articles and notes about liim and il is clear that he is a .strong
young man.
I did receive the medical authorization that wasforwarded and thank you for same.
I'lUbrlunalely. ilie hospital i.s being difllculi about releasing the records. First they would not
release ihem until your son had been discharged; and, now ihcy object to the aulhorizalion as it
was signed as '•parent* ofthe patient, .-\ccording to the records department, being that your son
IS over 18, they need for him to siî the authorization. As such, wc have included ojie for his
.signature.
Mr. Ledford cames quite a bit of insurance coverage thai would no doubt benefit your family in
this very dilllcull lime. As .soon as 1 am able to obtain the records, we w ill he able bring the
insurance portion of tins m.attcr to a condu.si(.m.
Please do not hc.sitalc to coniaci mc with an>' i|uesiions.
.Again, I hope that your son ainlinues to improve. 1 have jell my cell phono number below
which vou are free to call at any time.
Melinda Pitman
Serving Our Policyhoiders and Agents for More Than 95 Years Tuesday, May 9, 2017
— Lance Steinbeiss^RPR_csR
Cawthora v. Auto Owners

AO 00439
SiJicerely.
Pamela Mcl^nu CPCU,(Ext.8406)

dcaia.Branch Claims
(352)208-8574=
Cawthom v. Auto Owners

AO 00440
05 Property-Owners Ins. Co..
AUTHORIZATION FOR RELEASE OF MEDtCAL

AND EMPLOYMENTINFORMATION
Re; L6gerl Name; Claim.#:.
pate erf fiirtlii: .Acidcleiit date.:
Sefitiriity Number: or H- N.-.'

•Cencfer: M
Sy.my slgnature:beloWi..I.authoFlzerny-medicaJ.services provideri.emplGyer^.andforTnsuranceicarrieritb.:Teleasemedlcal.

and/or employmeaUnfarmatiDji;as de'serlbed below^ including biit not.limited to.pnotected health Information, to
AUtOr-OWrters Ihsiirahce Cothpany, IteafRllates, subsidlarJes, agehiSi.seiVants, attorneys ahd/dr eitiployees Ihqliiding
physiciahs^cdhdiictihgan ihaependehtJ^^^ e)cafhlhation df reyiew. This:riêaise aiithpd^s any health; qare;^^^^^
erhpioyer^ôr rn5ufer.t.o.projiffde>^ inTofrriatlpn without bohsepuence: dhder.lhe Health IhsLliahcePi^ and.
Aodpuntabill^t.Apl(HIPAA)or anyiother privacy lay^ and applicable regulations..
Theepeolfic medloal reeo.rcfe tope,released,are;.
AiT^rand all HIstp^^^^^ Exam ReportSi.^-Pay Repprfe, MRI ReportSi-GTS^ ReportSj Diagnostic Rlms/CDs,
.Adrriissiprîâ^^^ Reportej Cjinftaj Si^mariesv.Physlcia.h^^^ iûrsirig
Notesv Pathology Reports, RhyslGal Therapy Nbtesiv liiboratory Results anb i^nsuftaWon Reports.
The Employment RecordsTIf applicable^ to be released include but are not limited to., the personnelHle and wage and
.salary records for the two jteats prior to the dafe ofaccident provided above.
This authbrtzatioh ehatl Fernafiii lii fproe for3e.moiithsfdlJ6\(Vlhg the date ofitiyvstghature bNeloW^^ ahda copy ofthis
aUthorlzatTon is as.yalld.:as the original
J.uhderstand that;I may have cpntractu legal obngahori.s;taial!ow.aGce^^ to medica! and emp|oym:e.nt;jhformat1ony.
While 1 may revoke thls authorteatbnat any tlme.by provldi^^^ written notlflcatioh to the requestinig partyv ûnderstand that
nothing constitutes.a waiver.ofthe company^ rights .to such taformation under.contract or law and thatsuch revocation
win not have any affect on any actions taken.befbre;.lhe revocation was:received.
.T.uttderstand that anyIhfbrmatlpn thatis disGips^^ pursuant:to,this authpfizatlpn is.no longer covered by federal rules=
goverhlhg priyai^ and cohibehfialj^ informatioh, butsuch ih/pbiiation will not be;.fedlsci6s:ed byihe;reapieht.(s)
except;to parties buthpriieedto participate Ih eyaluatlbnbfinformatlbn fetat^ tp rriy daim or as recpjiredby few.
Any information requested byihis authonzation Istobe disclosed and used onlyfor puFpose&.crf the administration of
ciaims; determlhations of coverage andZor the provision of.behetits. A covered.entity nriay.not.cohdTflon treatment,
^yhient,enrPllriient, or ej|gibll% for fijehefBs..oh Pbtaihifig your authGrizatioh.. AutP-OwhefS rnsufahee;03mpa)^ 1S;.h^^
GoVeied;bhtity;
REFERTb STATE SPEClRC LANGUAGE ON PAGE 2 BEFORE SIGNJNG THIS FORM
Signature. Date
Circle Relationship to Patient: PatienfiParent / Legal Representative:
iai.22{T1-13}. P^^-1of:2:

AO 00441
(Applicable in Alabama Only)ALABAMA STATUTES PROVIDE THAT"Any person who knowingly presents afabe orftBUduIent daim for payment of a
loss or benefEt or who knowingly presents fsdse information in an application for insurance b guKy of a crime and may be subject to rîtutbn fines or
confinement In prbon, or any combination thereof."
(Applicable in Arizona Only)ARIZONA STATUTES PROVIDE THAT"For your protection, Arizona law rûires the fdiowing statement to appear on this
fomn. Any person who knowingly presents a feibe or fraudulent daim for payment of a bss is subject to criminal and civi penalties."
(Applicable in Arkansas Only) ARKANSAS STATUTES PROVIDE THAT"Any person who knowingly presents a fabe w fraudulent daim for payment of
a loss or benefit or knowingly presenb fabe informatbn in an appiicatbn for insurance is guilty of a crime and may be sutject to fines and corrfinement in
prison."
(Applicable in Colorado Only) COLORADO STATUTES PROVIDE THAT"it is unlawful to knowingly provide false, incomplete, or mbleading facts or
informatbn to an insurance companyfor the purpose of defrauding or attempting to defiaud the company. Penalties mîndude imprbonment,fines,
denial of insurance, and civil damages. Any insurance company or agent of an insurance company who knowingly provides false, incomplete, or mbleading
facts or informatbn to pdicyhdder w dalmantforthe purpose of defiiauding or attempting to defraud the pctteyhdder or claimant, with regard to a
settlement or award payable from insurance proceeds, shall be reported to the Cdotado division of insurance within the department of regulatory agencies."
(Applicable in Florida Only) FLORIDA STATUTES PROVIDE THAT"Any person who knowingly, and with intent to injure, defraud or deceive any insurer,
fa^ a statement of daim or an application containing any false, incomplete, or misleading information b guilty of a febny ofthe thrd degree."
(Applicable in Idaho Only)IDAHO STATUTES PROVIDE THAT"Any person who knowingly, and with intent to defraud or deceive any bsuance
company,files a statemerrt containing any false, incomplete, or mbleading informatbn b guilty of a felony."
(Applicable in Indiana Only) INDIANA STATUTES PROVIDE THAT"A person who knowingly, and with intent to defraud an insurer,files a statement of
daim containing any false, incomplete, or mbl^ding informatbn commits a felony."
(Applicable in Kentucky Only) KENTUCKY STATUTES PROVIDE THAT"Any parson who knowingly, and with Intent to defraud any insurance company
or other person,files a statemerrt of daim containing any materialy false informafion or conceab,forthe purpose of mbteading, irrformatbn concerning any
feet material thereto commib a fraudulent insurance act, which Is a crime."
(Applicable In Minnesota Only) MINNESOTA STATUTES PROVIDE THAT"A person who submite an applbatbn or fies a claim with intent to defraud or
helps commit a fraud against an insurer is guilty of a crime."
(Applicable In Ohio Only)OHIO STATLTTES PROVIDE THAT"Any person who,with intent to defraud or knowing that he b facilitating a fraud against an
insurer,submib an applicôn or files a daim containing a false or deceptive statement b guilty of insurancefraud."
(Applicable in Pennsylvania Only)PENNSYLVANIA STATUTES PROVIDE THAT"Any person who knowingly, and with intent to defraud any insurance
company or other person,fies an application for insurance or statement of cbim containing any materialy false informatbn or conc^b,for the purpose of
mbleading, informatbn concerning anyfeet material thereto commib a Iraudulent insurance act, whbh Is a crime and sutjects such person to criminal and
civil penalties."
(Applicable In Tennessee Only) TENNESSEE STATUTES PROVIDE THAT "It b a crime to knowingly providB false, IncompletB or mbleading Informafion
to an insurance company forthe purpose of defrauding the company. Penalties include imprisonment,fmes and denid of insurance benefrts."
(Applicable in Virginia Only) VIRGINIA STATUTES PROVIDE THAT"It Is a crime to knowingly provide false, incomptete or misleading information to an
insurance company for the purpose of defrauding the company. Penalties include imprisonment,fmes and denial of insurance beneTits."
18122(11-13) Page 2of2

AO 00442
Bob ledford's RV & Marine, Inc.

From; McLean, Pamela <McLean.Pamela@aolns.com>
Received; 7/18/2014 12:39:47 PM
To: 'mfo@dawsoncrr.com'<mfo@dawsonorr.com>
Attachments: Attachmenl.pdf
Please find attached the loss notice, summons and complaint and police report.
The remainder of the file is being sent to you via a separate email.
Thanks
Pamela T. McLean, CPCU

Senior Claim Representative Specialist
Ocala Branch Claims
(800) 437-6164x8406
Auto-Owners Insurance Company

P.O. Box 3200
Ocala, FL 34478
PLF EXHIBIT 13
Melinda Pitman
Tuesday, May 9,2017 Cawthom v. Auto Owners

Lance Steinbeisser RPR CSR AO 00392
FROM: McLean,ParDela<McLean.Painela@aoms.com>
TO: LegaLImageRightPiles
SENT: Friday, July 18, 2014 12:47:00 PM Eastern Daylight Time
SUBJECT: 56-00723-14 Bob Ledford's RV & Marine
This confirms our conversation regarding the suit hied against the Insured and the insured driver. As discussed, we sent
the suit for defense to Mike Orr. I instructed him to obtain medical documentation as soon as possible so that we can go
ahead and make our offer.
I will keep you updated.
Thanks

Ocala Branch Claims
(800) 437-6164x8406

P.O. 00x3200
Ocala, FL 34478
PLF EXHIBIT 14
Melinda Pitman
Tuesday, May 9, 2017
Lance Steinbeisser RPR CSR

AO 00574
Mosko, Alicia
From: Mbsko, Alicia <mosko.alicia@aoins.cdm>

Sent: Friday,July 18,2014 1:14 PM
To: mfo@dawsonorr.com
Subject: 56-723-2014
Please see the attached link to retrieve the file refereaiced above.
Download Instructions:
1. Click tliis imk: https://SecureFileTransfer.aoms.coni/message/RvH50L50Z3XgatCb51vCL2

2; Enter your email address.
3.. A second email will be sent to you. Click the link in the secxind email
4. Click tlie files fo download them. Ifthere are many files, you can dovraload them,all at once by
clicking the "Zipped Archive" button-
This etâfl or download Ihik caii bTOT be forwarded to anoth^ âil ^dress. If someone else in your office
needs access to tliis file, please contact youi* claims adjuster for apDro^•al. ALL questions regarding this
claim should be directed to the clauu adjuster.
The fiies are available until: Thursday,7 Angost

/-V
FQes attached to this message
Fflename CJierksuni(^HAl)
56-723r2014.pdf 10 MB
IB: E.yTJ50L50
"TtiiN site contain"! infai'mation that may bo privi{o(>otl and'or confidential aDd o.tompt from disclo.surc. Such information is
solely for(he intended use of the Recipiehi this email. Recipient agrees not to distiose any .vuch itiforniation 16 others, except as
alloei-cfi by iasv. Recipient s*1li defend, indemnify and hoid harmlcs.v Auto-Onnors Iij.viirjsncc Company from any claim or .suit for
d.iniagt'S arising out of the ili.s'closare or misuse of any .such information. Recipient liirther agrees to return, delete and/or deslro}-
alJ contcflt-s of this file after Us intended use."
PLF EXHIBIT 15
Melinda Pitman
_L3fit» Steinbasser RPR CSR

AO 00391
PH:man, Melinda
From: McLean, Pamela

Sent: Friday, July 18, 2014 4:07 PM
To: Pitman, Melinda
Subject: FW: Bob ledford's RV & Marine,Inc.
From: Michael R)x Orr imair

Sent: Friday, July 18, 2014 3:14 PM
To: McLean, Pamela
Subject: Re: Bob ledford's RV 8c Marine, Inc.
Pamela, my apologies during our call as I do know this firm, [actually served on the Florida Bar Board of Governors
with one of their named partners. I know you do not particularly care to hear it, but these are some of the best "big-
verdict" Plaintiff trial lavsryers around, particularly Erwin Gonzalez(he is not on the signature block of this pleading). I
am not sure about the lawyer they have running this case, but am gathering information in the interim. Just letting
you know we are not dealing with a loose operation on the other side. I am scheduled to speak with the insured on
Monday.-Mike
Sent from myiPad
On Jul 18, 2014,at 12:40 PM,"McLean, Pamela" <McLean.Pameia(5)aoins.com> wrote;
Please find attached the loss notice, summons and complaintand police report
The remainder of the file is being sent to you via a separate email.
Thanks

Ocala Branch Claims
(800)437-6164x8406
Auto-Owners insurance Company

P.O. Box 3200
Ocala, FL 34478
No virus found in this message.

Checked by AVG - www.avg.com
Version: 2012.0.2247 / Virus Database: 3955/7373 - Release Date: 07/18/14
<Attachment.pdf>
^HeVinda P-wa"

AO 00573
FROM:Pitman, MeIinda<Pitman.Melinda@aoins.com>
TO:Legal.ImageRight.Files
SENT: Monday,July 21, 2014 12:31:46 PMEastem Daylight Time
SUBJECT: FW: Bob Lcdford56-723-14
file

Sent: Monday, July 21, 201412:23 PM
To: Pitman, Mellnda
Subject: Bob Ledfdrd 56-723-14
Mike Ofrtold the me the plaintiffs firm Is a very good one. I have attached a link to their site.
http://vinA/w.colson.com/inthenews65.3Sp.htm

Ocala Branch Claims
(800) 437-6164x8406

P.O. Box 3200
Ocala, FL 34478
PLF EXHIBIT 17
Melinda Pitman
-—Lance Steinbeisser RER CSRL

AO 00572
■ Jul,22 1404:21 P ORANGE CITY COLLISION 386-668-1062 p.1
321EJH1GHBANKS RO
DEBAYFL 32713 O. C. COLLISION
38&6B8-6677
38M68-1062 CENTER
occ»llision@yahoo.cO(n
Fax
ToulOSEPH J. KALBAC JR From:O.C.COLLISION
Fax:(30S}45G-7444 Pages:5
Phone: Date: 07/22/14
Re: MADISON CAWTHORN 2007 BMW X3 WBXPC9347WF24IJ78
□ Urgent □ For Review □ Please Comment □ Please Reply □ Please Recycle
• Comments:. HERE IS ALL THE PAPER WORK I HAVE ON THIS 2007 BMW X3.
THIS CAR WAS TAKEN TO THE SALVAGE YARD FOR CRUSHING ON 06/12/14 PER OWNER.
THANK YOU,RANDY O.C.C.
ggSilBIiS
Melinda Pitman
Jul22 1404:22p ORANGE CITY COLLISION 386-668-1062 p.2
Colson
Hicks Joseph J. Kalbac, Jr.
l^nail: Jkalbac(^colson.com
JUJVjOVJJJ.. ^305)476-7430
Certlfled Mall
Return Receipt Requested
July 2,2014
Orange Citv Collission,Inc.

321 H.HIgiibanksRd.
l>eBary,FL327l3
Re: Madison Cawthorn

D/Loss! 04/03/2014
To Whom It May Concem:
Please be advised that T represent Madison Cawthorn,as a result of an accident that occurred on April 3,
2014 at approximately 4:57 p.ni., on eastbound Interstate 4 (State Road 400). Mr. Madison Cawthom
was a passenger in the 4-door tan 2007 BMW X3j Tag No. X406260, WBXPC93467WF24078, when it
proceeded to year off the road and collided with a concrete barrier. As a result, Madison Cawthom
suffered life threatening injuries including broken pelvis, vertebrae, paralysis, loss of kidney and broken
foot
This letter is to formally request that you please preserve tlie following evidence, as well as relevant
evidence associated or related to the subject accident and Madison Cawthorn*s injuries:
1) 4-door Tan 2007 BMW X3,TagNo.X406260,VIN NO. WBXPC93467WF24078
The vehicle is important evidence and by this letter I am requesting that you
take every measure to preserve the vehicle in exactly the same condition as
when h arrived at your facility.
2) All photographs ofthe subject vehicle taken at any time.
3) AU records, documents, regarding the subject vehicle, including but not limited to
. documents/evidence regarding its manufecture, purchase and repair.
If you are not willing to preserve the aforementioned cridcal evidence as requested, please contact me
immediately and advise me so that 1 may take appropriate measures to have this critical evidence
preserved. 1 would also like permission to come and inspect, test, and photograph the subject vehicle as
soon as possible.
yours.
J. KALBACJR. .
I ,TU£ Law Firm op Colsoh Hicks, Eidson. Golson. Matphews, Martinez,Gonzalez,Kalbac & Kane
'JjK/inm „
I 255 Alhambra Orcle, Femthouse I Coral Gables, Punuda|35134
I T: 305.476.7400|F; 305.476.7444|W: COLSON.COM
I 2101 LStbeef, N.W. 1 lOiH Floor j Washimcston, DC
| 20037
I 1:202,386.6706|F: 202.386.6706
I 600 C.ARONDELET SlRBCT,ROOMS 810 8r 812
|NEW ORLEANS, LA j 70130
; Ti 305.476.7400 j F: 305.476.7444
Jul221404:22p ORANGE CITY COLLISION 386-668-1062 p.3
Orange City Collision

24 Hour Roadside Sendee
321 EHighbanksRd
Debaiy, FL 32713
(386)775-6160
AprillO.2014
CustNo:1003
FIAHWY PATROL Date Towed:04/03/14
DELANO Conbol Mo:»6289
FL Invoice No:10042
RFI iMVQiCg
Vehicle: 07 6MWX3 VIN:WBXPC93467WF24078 SO T£^408244
RO:14-0284^ CdonBURNED
PC:
Re!ea8ed04/10/14
ReqBy:
Towed By:JH JOEH. Tru^ 0
OMie 0.0000 per ML.
Towing: 125.C0
FIRE 80.00
CASH 04/10/14 SENDING TTTLE Storage: 160.00
PAYOUT 0.00
2nd TOW 0.00
Labor 126.00
COVER 0.00
admit FEE 45.00
2nd man O.OO
Towed To: DEBARY GATE FEE 0.00

Towed From: 14 E.B.^120 M.M.
T^l Charges: 545.00
Stoced 8 DAYS@$20.00d}ay 7.80
Plus Tax:
Paid 04/10/14 Less Recelota: _512.80
Please pay This Amount 0.00
Date Towed:04/03/14 Date Re!eased:04/10/14 TOtSENDING TITLE
Print Name Of Person Picking Up Vehicle:
1. the underfed,do herebycerlily that!am legally authorized to take posesslon ofthe vehicle
Thte company Is not responsEblefor toss ordamages caused by feuHyftee,bumper bradt^,etc. and assumes no responsHayfor
toes wdamago byfhef^ fito. or any o#»rcause beyond oor control,to arv vehWe placed with ustor sioiBBo or repair.
Jul221404:22p ORANGE CITY COLLISION 386-668-1062 p.4
TOW COMPAMY COPY

FLORIDA HIGHWAY PATROL ^SERIKiiR
Pago 1 of1 FHPO14OFF028432
Vehicle Tow
cau^TV Wt msam^ !9?RfiOi7figP8Sr
4/3/20145:64:80 PM VOLUSIA DELANO 83716604
iFRSrNMIB
FtRSrNWIE MtDUENAUB
MtDOtENAUE LASTNAME SUFFKNATIE TClEPHmB
OAVID LB3FORD
6
AOORESS C/TY STATE 3PCOOE
ISaBOBLEDFORDDR 6REER SC 29651
□ OWNERPRaBOT OR □CWHERHOrBTOVnOW ATTEMPTED QYWER NOTTFICATTOH ATTBitPTS: Q OWWaH WOTFTCAEOW SUCCESSFU.
MMASFntST NAKCMDOLE LAST NAME SUFFRNAME 1ELB>H0K6
BRADLEY LEDFORD
ADDRESS cnv STATE ZIP CCDS
18 BROI»< MEADOWS LN AROEN NC 28704
YEAR MAKE KOOEL VEHlCLESmE VEKiaECOLOR TAOSTATE/NUMBER VN ODOMETER
2007 BMW X3 40 TAN SC X406280 WBXPC93487WF24078
ciCEMmr RED TAG DATE/TWE IDNUIUSER NME
REASON VBtlCLETOWS»
CRASH
pcwet YEAR coiOR wtTNa vEHCLB oanBtcmnoN NO. TA9KO. STATE DP.fiME
UMT
■HSS" VBAft CUM tlHrfna ' wDfiEUbaamcAVW^Mo. Twwr -SWS~BKB!tfg-
TRMlStI
TRIE- 1SK—gsrar ■wrar ■rosaBTSffSEiremB: ■W583- •msnsssmr
TRMLERZ
TOWSELECTIONTYFE UtCATIOMVEHIClE D^VEKTORIED/TDWED FROM

ROTATION WRECKBt EASTBOUND INTERSTATE 4
TOWING SBRMCE DAY TELEPHONE KISHr TELEPHONE
ORANGE CITY COLL 386-7764160 366-7764160
CTYr STATE/ap
321E. H1GHBANK3 KD, DEBARY. FL 32713
VEHCIE STORAGE LOCADOU OAVTaEFKONE MGHTTELB^KONC
ORANGE cmr COLL 386-7764160 386-7764160
ADDRESS cmrfSTATE/ap
321 E HI6HBANKS RD. OEBARY, FL 32713
□ CELUilAR PHONE 4NAK&M00EL1 QWKEEL COVERS INDICATE VEKiaE DAMAGE

OTY
□ RADAR DETECTOR (MAXEMOOEL) 0 1010 »AAn< AREA or DAMAGE
□ CUSTOM RJM3 □ undercarriage
<m
NUMBER OF TIRES <MCUJOe SPARE) OOVEHmiRM
n STEREO SVSTEU(RA1»0/C0/TAPE. ETC).
□WINDSKEU)
□ CB RAOtO/2 WAY RADtO □ trunk ACCESSIBLE
0FtRE
□ TRAILBlKirCH Qrearspoxer
□timlgr
PROPBRTV M VEKlCte
□ no DAMAGE
EVERYTHING BURNED
OFFICER COMMENTS
CRASH REPORT 83716804-01
WE THE UNDERSIGNED OFFICER(8) AND TOW DRIVER, HEREBY CERTIFY THAT THE ABOVE LISTED JOINT PROPERTY
INVENTORY IS CORRECT TO THE BEST OF OUR KNOWLEDGE.
StGNATtfilE OF TOW TRUCK DRIVai DATE SIGNATURE OF OFFiCER

RANK AND NAME OF OFFtCGR 0R6/UN1T LO. NUMBER
RBfRmDaeorrsmsnansNBr TPR K.M. RUEOE D 3401
• Jul221404:23p ORANGE CITY COLLISION 386-668-1062 p.5
BXLI> OF SALE
sfdX CO
• tlia fo2a.a«iQe as described belcw:
Le# jOdgoqater Hafldlogs

'A .—P"
tho anovnc ol oa th|4 date
V P£NAbTZt9 C9 imJUBSr, X DBCIARS XBAS X H4V5 BSAD TBE KBBOOIN6 BOCVUBNT ADD tlUX W
'fi sxMCso ZB z£ ioe laiias. ^
5ftllar*a eldnetura
|.d ZS0t-690-B8e NCismoo AJLio 3©MViio dcfiiMbi CO unr I

56-00723-14 Bob Ledford

From: McLean, Pamela <McLean.Pamela@aoins.com>
Received: 8/4/2014 1:37:44 PM
To: Legal.lmageRight.Files<Legal.lmageRight.Files@aoins.com>; mfo@dawsonorr.com<mfo@dawsonorr.com>
Attachments: Attachment.pdf
See attached health lien notice for payments to date ofjust less than 400k.

Ocala Branch Claims
(800) 437-6164x8406

P.O. 80X3200
Ocala, FL 34478
PLF EXHIBIT 19
Melinda Pitman
.Lance Stembeisser RPR.CSK

AO 00384
Fax Server 7/31/2014 8:25:08 AM PAGE 1/002 Fax Server
OPTUM www.optum.com
FAX
To: MCLEAN,PAMELA From: Sandy Harsh
Fax:(352) 873-9370 Fax: (800)708-3134 Ph (612)632-6733
Phone: Phone: +1(612)632-6733
Pages (Including Cover): 02 Thursday. July 31. 2014 8:08:24 AM CST
Comment:
Insured: BOB LEDFORD RV COMPANY

Insurer: AUTO OWNERS INSURANCE Claim 567232014
This facsimile transmission contains confidential information intended for the parties Identified above. If you have
received this transmission in error, please immediately notify me by telephone or return the original message at the
address listed above. Distribution, reproduction or any other use of this transmission by any party other than the recipient
is strictly prohibited.

AO 00385
Fax Server 7/31/2014 8:25:08 AM PAGE 2/002 Fax Server
OPTUM
MN102-0300
July 31, 2014 ConndmOat llOOOOptumCircte

Eden Prairie, MN 55344
www.optunn.com
Auto Owners insurance

Pamela Mclean
RE: Your Insured: BOB LEDFORD RV COMPANY

Your Claim Number: 567232014
Injured Party: David M Cawthom
Date of Injury: 04/03/2014
Group: EDWARD JONES COMPANY,#000183920
Our File Number: 24253811
Dear Pamela Mclean,
This letter is a follow up to our prior communications. Optum has been retained to pursue a recovery
for the medical benefits that have been paid arising out of the above captioned injury.
To date, medical benefits in the amount of $396,179.98 have been paid on behalf of David M
Cawthorn for the treatment of injuries sustained. The amount of paid benefits may increase. Please
contact us prior to settlement to obtain the total amount of paid benefits. Also, please include
Optum on the settlement draft at the time of settlement
Please note that the health plan is governed by the federal Employee Retirement Income Security Act
of 1974(ERISA), 29 U.S.C. §1001, et seq.
Please advise Optum of the current status of this matter.
Thank you.
Sincerely,
S2nd[rs.ha.'a>@cptum ccm
Sandra Harsh
Senior Analyst
Phone: 612.632.6733
Fax:800.708.3134

AO 00386
McLean, Pamela
/-s
From: Pitman, Melinda

Sent: Wednesday, August 06,2014 12:36 PM
To: McLean, Pamela
Ca Michael Fox Orr (mfc@dawsonorr.com)
Subject: 56-723-2014/Bob Ledfords RV & Marine Inc and 42-1134-2014
Pamela,
You have authority to tender the $3 million. Please work with defense to determine who should send a letter Indicating
that we are going to tender the limits. Also we should ask if Bradley has any insurance of his own if we haven't already.
Melinda A. Pitman, Attomey

(517)323-1201, ext. 6251
Pitman.Melinda@aoins.com
PLF EXHIBIT 20
Melinda Pitman
Tuesday, May 9,2017
Lance-Steinbeisser REfLCSR

AO 00430
Mick Callahan
From: Michael Fox Orr <mfo@dawsonorr.com>

Sent; Tuesday, August 05, 2014 10:25 PM
To: John Holcomb
Cc: Denise Devlin
Subject Re: Cawthorn v. Ledford, et al.
John, our prayers are with you and your family. I will be available when you have time. -Mike
Sent from my iPhone
> On Aug 5, 2014, at 9:34 PM,"John Holcomb" <john.holcomb@hwhlaw.com> wrote:

>
> Michael, my apologies for a late reply. I am under a lot of personal stress as my mother underwent 7 hours of brain
surgery yesterday and my attention is directed to her. I trust you can understand my relatively short and impersonal
reply to your e-mail.
> First, I tried to call Joe and was advised he was out of the country. That has probably changed, but I have been
preoccupied with my Mom.
> Second, I need to know more information before we can consult with Mr Ledford together. Any help you can
provide me will be helpful.
> I am only representing Bob Ledford RV, not his son. Have you be retained to represent both? I think Bob Ledford
RV will have a much stronger comparative negligence defense than his son,since there was no acquiescence on
their part to the plaintiff lying back with his feet propped up against the dashboard.
> Second, Mr. Ledford advised me that he was told by Auto Owners's that policy limits had been offered to settle this
tragic case. He said both the underlying policy and excess policy had been offered. However, he said he had no
correspondence from Auto Owner's to reflect this. If the policy limits have been offered, please provide me with
copies of the correspondence.
> I assume you will be removing this case to federal court. Please advise.
> Next, did Auto Owners's retain the vehicle so Plaintiffs firm can evaluate whether to pursue a product liability case
for the fire, seat belt, or potential air bag issues? Have they conducted an independent analysis of these potential
issues for a possible Fabre defense?
> After I hear back from you on these issues, I will be better prepared to discuss the case.
> I won't have time to discuss tomorrow as I am booked and spending time with my Mom.
> Thanks,
> John L. Holcomb
>
>
> On Aug 5, 2014, at 4:49 PM,"Michael Fox Orr" <mfo@dawsonorr.com<mailto:mfo(S)dawsonorr.com» wrote;

>
> John;
>
> Good afternoon. This email follows my voicemail left for you today. It is my understanding you were retained by
the Ledfords as personal counsel in regard to a lawsuit filed by Joe Kalbac on behalf of David Cawthorn. i also
understand that you might be reaching out to Joe and speaking with him about this case. I am assuming the
Ledfords have not yet told you I previously reached out to him and spoke with him. Given that I advised him of my
firm's representation and obtained an extension, i am hoping that you and I can get on the same page before you
call him so that we don't send mixed messages, etc. In that regard, I would like for you and I to talk as soon as
possible and get on the same page so that we can work toward resolving this matter.
>
> I have been advised you have a call with the Ledfords tomorrow morning at 11:00 a.m. If tlriie permits. It would be
great if I could attend the beginning or the end of that call so we can circle the wagons and I can advise you as to
where we are and cetanv thoughts and input you might have.
PLF EXHIBIT 21 Cawthorn v. Auto Owners

AO 00520
Melinda Pitman
Tuesday, May 9,2017
TPAIISMISSIQI I V'EPIFIOATIOil REPuRT
TIME 08/07/':01'1
IIAME AUTO OUIIERb UCALA EP
FA>: l?52&7:;;S:j70
TEL 1 B5:'873938S
SEP. I BR0J!:!J8573Sb
r'ATE.TTMF 08.''0? IP:39

fa;-; mo./mame lJiG5'^7S74ii4
DURATIGI I 00: OG:37
PAGE(S'5 03
RESULT OK
f-iOCiE STAIIDARD
Ei::M
AUTO O-'.'TIERS IMSURAMCt; COMPANY

AUTO''"'- "•vKN:-; Ul i. INijUKANPl COM!'ANY
!fOMC- ( ,MI1:P,5 IN?I.IRAM0K '."C'MPAMy
OVv'('iER •.'3LIRANCE COMPANY mes's
PROPIr' --O'A'NERS INSU('<AMC.- COt.l -/VNY
r«r,'l IT! K , OWNERS INOl iRANPr on: i-'AMY Life Hoiyr Car Busioess
7X.'. 'V:' •
BRANCH CLAIM OFFIClf

3220 ti.W. 31st Road, Suilc 201 » P.O. Box 3200
Ocala, PlorKlf 30478-3200
352-873.938a FAX 352-873-9370
WWW.AUTO-OWNERS.COIVI
CLAIMS PAX TRANf^lVIISSION
DAI I Number of page.^ including cover sheet J];;:-S
TO. FAX
.0
Iij
Alltihli'
FI'O 'Li '\mO-OV*/NLl';; lA!;.;tiNANCL COMPANY
BY' M' nuia Melinda Pitman

/I /
TuKday, May 9, 2017
RPR csR
AO 00370
AUTO-OWNERS INSURANCE COMPANY

AUTO-OWNERS LIFE INSURANCE COMPANY
HOME-OWNERS INSURANCE COMPANY
m
r^ OWNERS INSURANCE COMPANY ^xAuto-Owners Insurance
PROPERTY-OWNERS INSURANCE COMPANY
SOUTHERN-OWNERS INSURANCE COMPANY Life Home Car Business
IhtNoM&m'fhplk'
BRANCH CLAIM OFFICE

3220 S.W. 31st Road, Suite 201 •P.O. Box 3200
Ocala, Florida 34478-3200
352-873-938B FAX 352-873-9370
WWW.AUTO-OWNERS.COM
CLAIMS FAX TRANSMISSION
DATE: Number of pages including cover sheet
TO: FAX
TO:
Attention:
lljlMiocijL
FROM: JO-OWNERS INSURANCE COMPANY
BY: nuJ-A.
SUBJECT: (4^ (/
Remarks:
The information contained in this facsimile messaQO Is Intended only for the personal and confidential use of the designated rec[plont(s)
named above. This message may be an attorney-client or work product communication and is privileged and confidential. If you have
received this communication In error, please notify us Immediately by telephone and return the original message to us by mall. Any review,
dissemination, distribution or copying of this message by any person other than the Intended reciplent(s) or their authorized agents is strictly
prohibited. Thank you.
PLEASE CALL SENDER IF ANY PAGES ARE MISSING OR UNCLEAR

AO 00371
P.O. Box 3200

Ocala, FL 34478
PHONE(352)873-9388
ToU Free(800)437-6164
FAX(352)873-9370
August 7,2014
Sent via Facsimile without Attachments

Regular Mail with Attachments
Joseph J. Kalbec, Jr.

Colson Hicks Eidson
255 Alhambra Circle PH
Miami, FL 33134
Re: Our Insured Bob Ledford's RV & Marine, Inc.

Your Client David Madison Cawthom
Date of Loss 04/03/14
Dear Mr. Kalbec:
By way ofintroduction, my name is Pamela McLean and I am handling the insurance claim on
behalf of Bob Ledford's RV & Marine,Inc. and Bradley Bedford for the injuries sustained by
your client. As you are likely aware, we have relayed our desire to tender our insured's liability
coverage to your client upon receipt of any documentation ofthe injuries that he sustained in the
accident on the above mentioned date.
While we have not yet received any medical records, we did recently receive a notice oflien
from Mr. Cawthom's health insurance carrier. We have attached a copy ofthat notice that was
sent to us via facsimile on July 31,2013. After receiving this notice, we do feel that we have the
documentation necessary to tender the insured's coverage to your client. That coverage is in the
amount of$1 million under a garage liability policy and $2 million available under their
umbrella. We have attached two payments representing those limits as well as a copy ofthe
Declarations pages ofeach policy.
We are offering the coverage in exchange for a release ofthe named insured and the driver ofthe
vehicle, Bradley Bedford. Please contact me at your convenience so that we may reach an
agreement on a mutually acceptable release.

AO 00372
Should you have any questions or wish to discuss any aspect ofthis claim, please do not hesitate
to contact me.
Sincerely,
Pamela McLean, CPCU,(Ext. 8406)

Ocala Branch Claims
Cc: Michael Orr

Attorney at Law
50 N. Laura Street, Ste. 1675
Jacksonville, FL 32202
Cc: Jamie Moses

Attorney at Law
P.O. Box 3753
Orlando, FL 32801

AO 00373
FROM: McLean,Pamela<McLean-Pamela@aoins.com>
TO: OcalauClm.
SENT: Friday, August 08, 2014 9:58:52 AMF^tem-Daylight Time
SUBJECT:FW:Claim No. 56-723-2014 Cawthomv.Ledford, et. al
ATTACHMENTS: 1539_001.pdf;
From: Brooke S. Weedon [mailto:bsw@dawsonorr.com]

Sent; Thursday^ August 07,2014 4:56 PM
To: McLean, Pamela
Subject: Qaim No. 56-723-2014 Cawthom v. Ledfbtd, et. al
Good Evening Ms. McLean.
Please see the attached correspondence from Michael Fox Orr regarding the above referenced matter.
Apologies for sending this letter to your address, however,I doh'f believe I've ever sent correspondence to Ocala and
don't have die Ocala Claims e-mail address. J would assume ifs similar to Tallahassee's, however,T thou^t I might
verify tliatwith you inititally.
Thmk you in advance,
Brooke S."Weedon
ifegal Assistmit
tiAWSON I ORR
The Bank of AmericaTowfin
50 North Lauia Street
'Suite 1675
Jacksonville Florida 32202
(904)358-8300(p)
t904)358-8303 (f)
bsw@dawsonorr:com
www.dawsonorr.com
From:ocecopierll@gmall.com rmailto:ocecopiefll(S)gm3il.com]
SentiThursday, August 07,2014 4:40 AM
To: Brooke S. Weedon
Subject: Attached Image
PLF EXHIBIT 23
Melinda Pitman
I ani*.«5ti»inheiswet-HPn.CSB
Cawdiom V. Auto Owners

AO 00387
D^Won i Orr
FROFESSIONAL ASSOCIATION
Fox ORR;ESQplR£
CARL D. DAWSOM,EÛIRE. t<ÔVANNI STEWABT.£SQUK£.
{904)055-5505 (P) fEKEMY M. Paul. Esquike
(904J 357-5534 (F) jlÎCA R. CREPGAN. ENQUIRE
August 7,2014
OE COUNSEL
Amanda fermlle,esquise-
PklVlLEGED & CONFIDEÎAL
Protected BY ATiioiRNiEiMirLiE^ i(^>4)35&a300 (F)
^Work Product Privileges (904)iy56-S303(P)
¥1A ELECTRONIC MAIL

Pamela T* McLean,CPCU
Senior Claim Represraitative Specialist
Ocâ Branch Claims
P;0. Box 3200
Ocala, FL 34478
ite: David Madison Cawtiiom y, Bradley Ledford aaid Bob Lôrd's RV &
Marine
Case No.: 2014-11310
Our File No: BlOOO-410
ClaimNo.: 56-723-2014
Dear Ms.McLean:
ITiis letter acknowledges your rec^t assignment ofIhe &ve ieênced lawsuit t6 our
finn. Vou have asked us to represent Bob Ledford's RV & Matuie. In that rejgagi, we have
contacted the insured to discuss the allegations Found iinihe Complaint apiiJ plan for th§ defense
ofthis case. It is my understanding that Auto^wners has retain)^ separate counselto represent
jVfr. Bradley Ledford m matter.
have rîyed die. glaiin file, hdWeyer, iF tiiiere: affc any gtidirional documents please
provide copies at ypur-^liest convenience. Thank you again ibr your wntiidence in pur firm
andjilease do not hesftatcto contact me if you should^h^^ê any questions in the future.
yerytrul
fekNK OF America Tower 156 N.Laura STOEETvSunE tSTS Jacksonville. fL.pRiDA 32202
Vp'W\DjA\VS6NOR R.COM

AO 00388
FROM:Pitman, Melinda<Pitman.Melinda@aoins.com>
TO:I:«gal.ImageRight.Files
SENT: Monday,August 11, 2014 11:30:24 AM Eastern Daylight Time
SUBJECT; FW: 56^0723-14 Bob Ledford's RV & Marine,Inc.
ATTACHMENTS: Attachmentpdf;
file

Sent: Friday, August 08, 2014 10:22 AM
To; mfo@dawsonorr.com; Jamie Moses(jnioses^tfisheriawfiimcom)
Cc; Pitman, Meiinda
Subject: 56-00723-14 Bob Ledford's RV & Marine,Inc.
See attached letter that wassent to the plaintiffs attorney along with the two payments.
Thanks,

Senior Claim Representative Spâlist
Ocala Branch Claims
(800)437-6164x8405

P.O. Box 3200
Ocala, PL 34478
BglSgBSE!
Meiinda Pitman
I unrf Sfpintvisftpr RPR CSR>

AO 00545
Autu-Ov/iicis linuiuiicc Comiidiiy

Autu-Uvviifis lilu liKUKince (oiiipiKiy
ItDnic-Uwiicis liiûiQiice (ompany
Dwiieis liisuintue (ompmiy ^ûto-OwnersInsurant
rioiicily-Ov/iieis IntuiniKC (ompiiny Life Home Car Business
Suulhcrn-Uwiitils Insuiance Compony
P.O. Box 3200

OcaIa,FL 34478
PHONE(352)873-9388
ToU Free(800)437-6164
FAX(352)873-9370
August 1,2014
Sent via Facsimile without Altaciunents

ReguLir Mail with AttachnieiUs
Joseph J. Kalbec, Jr.

Colsoii Hicks Eidson
255 Alhambra Circle PH
Miami, FL 33134
Re: Our Insured Bob Ledford's RV & Marine,Inc.

Your Client David Madison Cawthom
Dale ofLoss 04/03/14
Deal' Mr. Kalbec:
By way ofintroduction, my name is Pamela McLean and I am handling the insurance claim on
behalfofBob Ledford's RY & Marine, Inc. and Bradley Ledford for the injuries sustained by
your client. As you are likely aware, we have relayed our desire to tender our insured's liability
coverage to your client upon receipt ofany documentation oftlie injuries that he sustained in the
accident on tlie above mentioned date.
Wliile we have not yet received any medical records, we did recently receive a notice oflien
from Mr. Cawthorn's health insurance carrier. We have attached a copy ofthat notice that was
sent to us via facsimile on July 31,2013. After receiving tliis notice, we do feel that we have the
documentation necessary to tender the insured's coverage to your client. That coverage is in the
amount of$l million under a garage liability policy and $2 million available under their
umbrella. We have attached two payments representing those limits as well as a copy ofthe
We are olfermg the coverage in exchange for a release ofthe named insured and the driver ofthe
vehicle, Bradley Ledford. Please contact me at your convenience so that we may reach an
agreement on a mutually acceptable release.
Serving Our Poiicyhoiders und Agents for More Than 95 Years

AO 00546
Should you have any questions or wish to discuss any aspect of this clahu, please do not hesitate
to contact me.
^me
mela McLean,CPCU,(Ext. 8406)
Ocala Branch Clamis
Cc: Michael Orr

Attorney at Law
50 N. Laura Street, Stc. 1675
Jacksonville, FL 32202
Cc: Jamie Moses

Attorney at Law
P.O. Box 3753
Orlando,FL 32801

AO 00547
Melinda Pitman
l.anrp Sfpinftftj^spr RPR f^R
Michael Fox Orr <mfo@dawsonorr.com>

08/14/2014 at 04:40 PM
From: Michael Fox Orr <mfo@dawsonorr.com>

08/14/2014 at 04:40 PM
John Holcomb <john.holcomb@hwhlaw.com>
Penise Devlin <denise.devlin@hwhlaw.com>. cdd@dawsonorr.com ,
Amanda E. Ferrelle <aef@dawsonorr.com>, Brooke S. Weedon <bsw@dawsonorr.com>
John.
1 am glad to hear of your mother's recovery.
Your statement below about when Auto-Owners paid infers that you believe it should have been paid earlier.
When do you believe it should have been paid? The file I have received and the information I received from my
client who is represented by David Ledford, reflects that no pre-suit demand was ever made. Do you have
different information? Regardless of what Auto-Owners did or did not do, my only concem is protecting the
interest of our mutual client. If there is information I do not know about that affects that representation, I would
ask that you advise us (Carl, Amanda, Brooke & me)of that information as soon as possible.
I understand also from your statement below that you will not be appearing in the case. However, we will
provide you with copies of any and all relevant pleadings and discovery responses. We will also copy you on
all correspondence to the client moving forward. If at any point, you believe Auto-Owners should be doing
more to protect our mutual client, please forward that statement to Auto-Owners directly. Conversely, if you
believe that I should be doing more to protect our mutual client or you would like to discuss any strategy
decisions, please let me know.
We are working to schedule the inspection of our expert engineer for August 26,2014 and are awaiting
confirmation. We will let you know the date and time in case you would like to be present.
Below you ask that I limit communications with my client. 1 am not aware of a limited appearance that i have in
this litigation. At the same time, I am not here to address any insurance coverage issues and am not aware of
any insurance coverage issues. With that said, what are you referring to below in requesting I limit
communication with my client?
I have copied my partner, Carl Dawson, another attorney in my office, Amanda Ferrelle. and my paralegal.
Brooke Weedon. Should you need anything and I am not here, please reach out to one of them. Thank you.
-Michael
Michael Fox Orr, Esquire

DAWSONIORR
The Bank of America Tower
50 North Laura Street
■ From: John Holcomb [mailto:john.holcomb@hwhlaw.coml

Sent: Friday, August 15, 2014 12:44 PM
To: Michael Fox Orr
Subject: Re: Cawthorn v. Ledford. et. al.
Michael as soon as David Ledford called me and toid me that this young man,a future Naval academy cadet,
vras paralyzed almost died, was in ICU for an extended period of time, had severe internal injuries and burn
knew policy limits should have been offered, David was told they were. What in the heck changed on August
7? I lost my first paraplegic jury trial over 20 years ago for much more than $ 3 million dollars. Thank goodness
my client had more insurance than that.
We do agree that Auto Owner's should not be your focus, as Ledford is your client.
John L Holcomb
PLF EXHIBIT 26
Melinda Pitman
l.sfifw .StPinhPisLW RPR CSR
Fwd: Cawthorn v Ledford, et al
Mick Csiishsn ^rnick@mickC3ll3h3nIaw.corn> Auq 15 2014 at i'2S PM

To; Christina Carlson-McCioskey <christina@mickcal!ahanjaw.com>
Forwarded message
From: Mick Callahan <mick@mickca}lahanlaw.com>
Date: Fri, Aug 15. 2014 at 1:26 PM
Subject: Cawthorn vLedford, etal
To: mfo@dawsonoiT.com
Dear Mr. Orr

I represent Bradley Ledford who was an insured dri\er under one or more Auto Owners poIiciK at the time of
an accident on 4-3-14 which severely injured Madison Cawthorn in Volusia County, Florida. I understand that you
represent Auto Owners interest in this matter.
From my brief preliminary investigation of the adjustment of this claim, it appears as if Auto Owners has had
tittle or np communication with Bradley regarding the investigation, adjustment, and attempts to resolve the claim
within policy limits. This was a catastrophic injury involwhg paralysis and bums and internal injuries where the
economic damages alone far exceed coverage and liability is not a real issue. My understanding is that no offer
was ever made to Joe Kalbac, who represents the Piaintitf, until last week, over four months after Auto Owners
knew of the accident details, and that Mr. Kalbac is not inclined to resolve the claim within policy limits at this
time because of the delays occasioned by Auto Owners. Of course. I am hopeful that 1 am mistaken and that
your client's files reflect otherwise.
Please provide me with a copy of your client's entire claim file to date and any correspondence generated by
the adjusters or supervisors to date associated with this claim against my client and the lawsuit filed.
I have been in communication viith Jamie Moses of the Fisher law timi in Orlando who has been assigned to
cefend Bradley and we are fully cooperation with any other requests. I am somewhat concerned that Mr. David
Udford reports that no effort was made by Auto Owners to retain the vehicle for purposes of investigaing possible
third pai^ or Fabre fiability, especially In light of seat belt and fire issues in the case. Again, hopefully my
information is mistaken. Please fully advise of the details and provide all documents relating to the consideration
of retention and of salvage of the vehicle.
Ail of my requests in this correspondence include a request for any electronic versions of documents.
Thanks in advance for your cooperation. I look forward to working with you to get this matter folly resolved on
behalf of my client.
Sincerely,
PLF EXHIBIT 27
Attorney at Law Melinda Pitman
.2935 1st Avenue Kortn, Suite 2
Tuesday, May 9,2017
1 anr*> Sfpinhpisspr RPR CSR
Cawthorn v. Auto Owners

AO 00140
* St. Petersburg,FL 33713

Phone:727-209-1504
Fax:727-502-9621
E-maU: mick(®miclscaI]ahanlaw.coin
Website:\™\Mnickcallahanla\<-.co m
Cor^dentiak This e-mailcontain a communication protected by die attomey-cUentpnvilege or constitutes work

prpducL Ifyou do notexpectsuch a communicadon please delete this message withoutreading itor any attachment
and then notijy the sender ofdiisinadvertentdelivery.
Micbael T»C^lahiM,Attorney at Law

29351St Avenue North,Suite 2
St. Petersburg,FL 33713
Phone:727-209-1504
Fax:727-502-9621
E-mail: mick@mickcaliahanlaw.c6m
Website:xwvv.mickcallahanlaw.com
Cpnfidendal: This e-maiIcontains a communicgtioh protected by the attomey-cHentprivilege or constitutes work

pro uct Ifyou do notexpectsuch a communication please delete this message mthoutreading itor any attachment
and then nodfydie sender ofthis iiiadvertentdelivery.
Michael Callahan <mick@mlckcaIlahanlaw.com> Men, Aiig 18, 2014 at 5:27 PM

To: Cnnstina Carison-McCloskey <christina@mickcaIlahanlaw.com>
Part of corr file in case pl^se. M
Sent from my iPhone
Begin forwarded message:
From: Michael Caliahan <mick@rTiickcallahanlaw.com>

Date: August 18, 201,4 at 4:26:34 PM CDT
To: Michael Fox On'<mfo@dawsonorr.com>
Subject: Re: Cawtfiorn v Ledford, et ai
Thanks, Michael. Who does

If you know? Mick
Sent from my IPhone
On Aug 18, 2014i at 4:^ PM,Michael Fox Orr <mfo@dawsonorr.com> wrote:
Mr.Caliahan:
Thank you for your email. 1 am riot sure where you obtained j'our.injformation>
butI do;not represent Auto-Owners. trepresenl Bob Ledford's RV & Nferine. I
recommend you forward whatever requests regarding claims issues and Autp-
Ovvners'decisions to Auto-Owners.

AO 00141
McLean, Pamela
From: Jamie Moses <jmoses@fisherlawfirm.com>

Sent: Monday, August 18,2014 2:58 PM
To: McLean, Pamela
Subject: Cawthorn 56-00723-14
Thank you for the authorization to conduct the necessary research on the file.
I Just spoke with Plaintiffs counsel. He said they will not be accepting the tender. He claimed there was other
information he wanted to see, but would not specify what. He agreed to an extension of time on the Answer to
Monday, August 25, 2014. I have a telephone conference on Friday with Bradley and his personal counsel, Michael
"Mick" Callahan.
Based on what I have received to date, I believe we should engage in some investigation and informal discovery such as:
1. Interviewing the witnesses to the accident;

2. Possibly retaining an accident reconstructionlst;
3. Based on what you reported to me,the car has been destroyed, but in the event that is not accurate, an
inspection of it would be wise;
4. A biomechanical engineer may be necessary to explore the potential argument that the position of Maddison's
legs on the dash contributed to his injuries(due to the airbag deploying);
5. Retaining a spinal specialist given Maddison's injuries.
We may want to work with Atty Orr and share experts to the extent we can. Obviously, if we did that, we'd need to
have some sort of agreement the expert could still be used (and paid for) if his client were to get out of the case.
if you have received any additional materials on this matter, I would appreciate you sending them to you.
Jamie Blllotte Moses, Esquire
Board Certified Appellate Specialist

Certified Circuit Civil Court Mediator
Rsher Rushmer, P. A.
390 North Orange Avenue
Suite 2200
Post Office Box 3753
Orlando, Florida 32801-1642
407-843-2111
407-422-1080 (Facsimile) PLF EXHIBIT 28
www.flsherlawfirm.com
Metinda Pitman
FISHER RUSHMER Tuesday, May 9, 2017
1 anrp ."=?tPinhPiRS#>r SPR PJ^R
PLEASE NOTE EFFECTIVE IMMEDIATELY OUR POST OFFICE BOX ADDRESS HAS BEEN CHANGED TO P.O. BOX 3753,
ORLANDO, FL 32802-3753

AO 00345
CONFTOENTIAL:The information in this email(including any attachments)is confidential and may be privileged. If you are not the
intended recipient, you may not and must not read, print, forward, use or disseminate the information contained herein. Although this
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recipient ofthis message, please rqily to the sender and include this message and dien delete this message from your inbox and your
archive and/or discarded messages files. Any unintended disclosure oflegally privileged and/or confidential information that may
have occurred is inadvertent and does not constitute a waiver of any such privilege or confidentiality. Thank you.
IMPORTANT;Fisher Rushmer,P. A utilizes spam and junk e-mail filtration applications in its e-mail information systems. These
applications may prevent or delay delivery of certain e-mail commumcations. If you do not receive a timely response to an e-mail
communication, please contactthe intended recipient via telephone at 407-843-2111.
IRS CIRCULAR 230 NOTICE:Pursuant to Treasury Department Circular 230,this is to advise you unless we otherwise ejqiressly
state in writing, e-mail communications,including all attachments, from this firm are not intended or written to be used, and cannot be
used,for the purpose of avoiding tax-related penalties. If you wish to engage this firm to provide formal written advice as to federal or
state tax issues, please contact the sender.

AO 00346
WHck Cnllah;=i!^ <rnli^t<@mickColl^'{iUHilP5W.(;aj

m 9
LyCÔ0^:[Ic
e; Cawthorn v Ledford, et al Cawthorn v Ledford; Claim No. 56-00723-14
ck Callahan <mick@mickcallahanlaw.cx)m> Thu, Aug 21,2014 at 3:46 F

•: McLeanPamela@aoins.com
Dear Ms. McLean:
I am personal counsel for /Vito Owners for Bradley Ledford. I just got Involved in this matter and have acquired infoimatior
Tom the Ledfords and from your assigned counsel for my client, Jamie Moses. I have attached an email that 1 sent to Mr. Orr
ihlnking he was Auto Owners counsel when I first got involved, and his response. He advised me that he represents the
/ehicle owner as assigned counsel so I would like you to consider the attached letter as addressed to you as Auto Owners
•epresentative.
^lease provide the Information and documents requested In my letter to Mr. Orr promptly so that I can be fully informed as to
/vhat has transpired to date.
Ms. Moses has also informed me that the PiaintifTs counsel has in fact now rejected the tender of policy limits so that my
Diient is potentially exposed to amounts in excess of Auto Owners policy limits. I have also recieved documentation since that
etter was written to Mr. Orr that Mr, David Ledford made inquiry about the vehicle salvage from Auto Owners agent and was
old that the vehicle could be disposed of. Both of these matters concern me as there may be spoliation of evidence
lecessary to defend my client or to seek shared legal responsibility and there may have been a real chance at settlement of
:his daim against Brad within policy limits that was not pursued or was blown by Auto Owners by it's failure to be proactive in
settling the claim.
Thanks for your prompt attention to these matters.

Sincerely, Mick Callahan
Michael T. Callahan,Attomey at Law

29351st Avenue North, Suite 2
3t. Petersburg, FL 33713
Phone: 727-209-1504
Fax:727-502-9621
E-mail; mick@niickcallahanlaw.com
Website: www.niickcallahanlaw.com
Confidential: Thise-moll contains a comm«n/ca£7o/i protected by the attorney-client privilege or constitutes work product. Ifyou
io notexpectsuch a communication please delete this message without reading it or any attachment and then notify the sender of
diis inadvertent delivery.
Pi Re Cawthorn v Ledford et al.msg

^ 33K
ck Callahan <mick@mlckca!lahanlaw.com> Thu, Aug 21,2014 at 3:47 F

•: Joni Canterbury <joni@adventuremotorhomes.net>, John Holcomb <]holcomb@hwhlaw.com>
^lease note my communication to Auto Owners. Mick
Quoled lexl hidden) —
□ Re Cawthorn V Ledford et al.msg

33K Melinda Pitman
/"uesday.Mayg. 2017

AO 00542
Michael T. Callahan
ATTORNEY AT LAW
2935 isT AVENUE North TELEFHONE (727) 209-1504

Michael T. Callahan
SUITE 2 Facsimile (727) 502-9621
Admitted in Utah: Florida: MICK®M1CKCALLAKANLAW.COM
CERTIFIED CIRCUIT CIVIL MEDIATOR St. PETERSBURG. FLORIDA 33713
www.mickcallahanlaw.com
September 10,2014
VIA EMAIL: MCLEAN.PAMELA@.AQINS.CQM

PC Box 3200
Ocala, FL 34478
Re: Cawthom v. Ledford, et al.

Policy Number: 48-901-965-00
Claim No.: 56-00723-14
Dear Ms. McLean:
I have attached three pages of emails and my correspondence to you of August 21, 2014.
As of this date, I have heard nothing back from you in response to my prior requests.
My client, Bradley Ledford, again requests that you provide him the information I
requested including the entire claim file to date, including particularly, copies of any
communications by Auto-Owners to him or to his father, David Ledford, any communications
regarding the tender of my client's policy limits and the acceptance or rejection of same by Mr.
Cawthom's attorney, Joe Kalbac, and all commQnications regarding the preservation of the
vehicle involved in the accident, from your files or the agent's files.
I look forward to your prompt communication.
Sincerely.
ael T. Ca
MTC/sll
cc: Mr. Bradley Ledford, via U.S. Mail
Mr. David Ledford, via Email
PLF EXHIBIT 30
Melinda Pitman
I annp .«^fpinhPi«L<5far RPR flRH

AO 00517
Christina Canson-McClosKey <christina@mickcanahaniaw.cotT;>

tyC.ooglo
Fwd: Cawthorn v Ledford, et al

4 messages
Mick Callahan <mick@mickcalIahanlaw.com> Fri, Aug 15, 2014 at 1:28 PM

To: Christina Carlson-McCloskey <chrlstina@mickcaHahanlaw.com>
Forwarded message
From: Mick Callahan <mick@mickcallahanlaw.com>
Date: Fri, Aug 15, 2014 at 1:26 PM
Subject: Cawthorn v Ledford, et al
To: mfo@dawsonorr.com
Dear Mr. Orr:

I represent Bradley Ledford who was an insured driver under one or more Auto Owners policies at the time of
an accident on 4-3-14 which severely injured Madison Cawthorn in Volusia County, Florida. I understand that you
represent Auto Owners interest in this matter.
From my brief preliminary investigation of the adjustment of this claim, it appears as if Auto Owners has had
little or no communication with Bradley regarding the Investigation, adjustment, and attempts to resolve the claim
within policy limits. This was a catastrophic injury invelving paralysis and bums and internal injuries where the
economic damages alone far exceed coverage and liability is not a real issue. My understanding is that no offer
was ever made to Joe Kalbac, who represents the Plaintiff, until last week, over four months after Auto Owners
knew of the accident details, and that Mr. Kalbac is not inclined to resolve the claim within policy limits at this
time because of the delays occasioned by Auto Owners. Of course, I am hopeful that I am mistaken and that
your client's files reflect othenvise.
Please provide me with a copy of your client's entire claim file to date and any correspondence generated by
the adjusters or supervisors to date associated with this claim against my client and the lawsuit filed.
I have been in communication with Jamie Moses of the Fisher law firm in Orlando who has been assigned to
defend Bradley and we are fully cooperation with any of her requests. I am somewhat concemed that Mr. Davd
Ledford reports that no effort was made by Auto Owners to retain the vehicle for purposes of investigaing possible
third party or Fabre liability, especially in light of seat belt and fire issues In the case. Again, hopefully my
information is mistaken. Please fully advse of the details and provide ail documents relating to the consideration
of retention and of salvage of the vehicle.
All of my requests in this correspondence include a request for any electronic versions of documents.
Thanks in advance for your cooperation. I look forward to working with you to get this matter fully resolved on
behalf of my client.
Sincerely,
MichaelT.Callahan,Attorney at Law
2935 1st Avenue North,Suite 2
Cavvthom v. Auto Owners

AO 00518
St. Petersburg, FL33713
Phone:727-209-1504
Fax:727-502-9621
E-mail: mick@mickcallahanlaw.com
Website: www,mickcallahanlaw.com
Conftdentiai: This e'tnail contains a communication protected by the attorney-client privilege or constitutes work
product Ifyou do notexpectsuch a communication please delete this message without reading it or any attachment
and then notify the sender 0/this inadvertent delivery.
Michael T.Callahan,Attorney at Law

2935 1st Avenue North, Suite 2
St. Petersburg, FL33713
Phone: 727-209-1504
Fax:727-502-9621
Website: www.mickcallahanlaw.com
Confidential: This e-mail contains a communication protected by tae attorney-client privilege or constitutes work
product Ifyou do not expectsuch a communication please delete this message without reading it or any attachment
and then notify the sender ofthis inadvertent delivery.
Michael Callahan <mick@mlckcaliahanlaw.com> Mon, Aug 18, 2014 at 5:27 PM

To: Christina Carison-McCloskey <christina@mlckcaiiahanlaw.com>
Part of corr file In case pleAse. M
Sent from my iPhone
Begin forwarded message:
From: Michael Callahan <mick@mickcallahanlaw.com>

Date: August 18. 2014 at 4:26:34 PM COT
To: Michael Fox Orr <mfo@dawsonorr.com>
Subject: Re: Cawthorn v Ledford, et al
Thanks, Michael. Who does

If you know? Mick
Sent from my iPhone
On Aug 18, 2014, at 4:22 PM, Michael Fox Orr <mfb@dawsonorr.com> wrote:
Mr.Callahan:
Thank you for your email. I am not sure where you obtained your informa tion,
but I do not represent Auto-Owners. I represent Bob Ledford's RV & Marine. I
recommend you forward whatever requests regarding claims issues and Auto-
Owners'decisions to Auto-Owners.

AO 00519
Mick Callahan
Fi-ojn. Michael Fox Orr < mfo@dawsonorr.com>

ggpt; Tuesday, August 05,2014 10:25 PM
To: John Holcomb
Cc: Denise Devlin
Subject Re: Cawthorn v. Ledford, et al.
John,our prayers are with you and your family. I will be available when you have time.-Mike
Sent from my iPhone
> On Aug 5,2014, at 9:34 PM,"John Holcomb" <john.holcomb@hwhlaw.com> wrote:

> Michael, my apologies for a late reply. I em under a lot of personal stress as my
surgery yesterday and my attention is directed to her. I trust you can understand my relatively short and impersonal
^Fir^stJ tried to"call Joe and was advised he was out of the country. That has probably changed, but I have been
preoccupied with my Mom. . ,
> Second, I need to know more information before we can consult with Mr Ledford together. Any e p you can
provide me will be helpful. u •u-j i q^k i oHfnrH
> I am only representing Bob Ledford RV, not his son. Have you be retained to represent both? i think Bob Led o
RV will have a much stronger comparative negligence defense than his son,since there was no acquiescence on
their part to the plaintiff lying back with his feet propped up against the dashboard. » „j .-„i-,hk
> Second, Mr. Ledford advised me that he was told by Auto Owners's that policy limits had been offered to settle this
tragic case. He said both the underlying policy and excess policy had been offeredJHowever,he said he had no
correspondence from Auto Owner's to reflect this. If the policy limits have been offered, please provide
copies of the correspondence.
> I assume you will be removing this case to federal court. Please advise. . ^ ujiu,, --ea
> Next, did Auto Owners's retain the vehicle so Plaintiffs firm can evaluate whether to pursue a product liability case
for the fire, seat belt, or potential air bag issues? Have they conducted an independent analysis of these potential
issues for a possible Fabre defense?
> After I hear back from you on these issues, I will be better prepared to discuss the case.
> I won't have time to discuss tomorrow as I am booked and spending time with my Mom.
> Thanks,
> John L. Holcomb
>
> On Aug 5,2014,at 4:49 PM,"Michael Fox Orr" <mfo@dawsonorr.com<mailto:mfo@dawsonorr.com» wrote:

>
> John;
> Good afternoon. This email follows my volcemail left for you today. It is my understanding you were retained by
the Ledfords as personal counsel in regard to a lawsuit filed by Joe Kalbac on behalf of David Cawthorn. I also
understand that you might be reaching out to Joe and speaking with him about this case. I am assuming the
Ledfords have not yet told you I previously reached out to him and spoke with him. Given that I advised him of my
firm's representation and obtained an extension, I am hoping that you and I can get on the same page before you
call him so that we don't send mixed messages,etc. In that regard, I would like for you and I to talk as soon as
possible and get on the same page so that we can work toward resolving this matter.
> I have been advised you have a call with the Ledfords tomorrow morning at 11:00 a.m. If time permits. It would be
great if I could attend the beginning or the end of that call so we can circle the wagons and I can advise you as to
where we are and cet anv thoughts and input you might have.
AO 00520
$0.69C
us POSTAGE
ÎRST-ClAss
0S2S0006D087SIJ
337?3
Michael T. Callahan
ATTORNEY AT lAW
.29X' 1»» AVTNUE NoriH
MUTE 1
ST PjrrEHSllL'ltC, FLORIDA 33713
Ms. îclinda I'jlman

Autti-Ouncrs I nsiirancc ComfUii.
(>101 Ariacapii Blvd.
Lansing, Ml 4X9)7
4S9i7asssoi

AO 00521
FROM:Pitman, MeIinda<Pitman.Melinda@aoins,com>
TO:Jtegal.ImageRight.Files
SENT: Wednesday, September lO, 2014 3:40^53 PM Eastern Dayli^t Tim0
SUBJECT: FW: Cawthomv. Ledford, et al.
ATTACHMENTS:Ltr Pam McLean.pdf;
Task
56-723-2014 and 42-1134-2014

Sent; Wednesday, September 10, 2014 3:32 PM
To: Pitman, Mellnda
Subject: FW: Cawthom v. Ledford, et al.
From: Sherri LaFerrara rmailto:shern@mickcallahanlaw.com1

Sent: Wednesday, September 10, 2014 3:31 PM
To: McLean, Pamela
Subject: Cawthorn v. Ledford, et ai.
In connection with the above-referenced matter,"pleê find attached correspdhdeh'cd from Mr. CÎIahan 10701/. Thank
you.
Sherri L.LaFerrara - Legal Assistant

;2935 First Avenue North, Suite 2
Sl Petersburg,FE 33713
Phone: (727)209-1504
Fax: (727)502-9621
Email: sherTi@.mickcallzihaD]aw.com
Website: wv^.mickcallahanlaw.com
Melinda Pitman
- I flnraa .<5fwnh<»is,«aar ppp
V.'

AO 00143
Michael T. Callahan
ATTORNEY AT LAW
Michael T. Callahan 2935 1ST AVBNUE NORTH TtLEPHONB (727) 209-1504

SUITE 2 FACSIMILE (727)502-8621
ADlttTTED IN UTAH; FLOKIDA;
CERTIFIED CtRCUIT ClVlL MEDIATOR ST. PETBRSBURO, FLORIDA 33713 auckSmickcallahanla-vkcoh
WWAUCKCALLAHANLAVKCOM
September 10,2014
VIA EMAIL: MCLEAN.PAMELA@AOINS.COM
Pamela T. McLean,CPCU
PO Box 3200
OcaIa,FL 34478
Re: Cawthom v. Ledford, et al.

Claim No.: 56-00723-14
Dear Ms. McLean:
I have attached three pages of emails and my correspondence to you of August 21,2014.
As ofthis date, I have heai'd nothing back from you in response to my prior requests.
My client, Bradley Ledford, again requests that you provide hhn the infonnation I
requested including the entire claim file to date, including particularly, copies of any
communications by Auto-Owners to him or to his father, David Ledford, any communications
regarding the tender of my client's policy limits and the acceptance or rejection of same by Mr.
Cawthom's attomey, Joe Kalbac, and all commClnications regarding the preservation of the
vehicle involved in the accident, from your files or the agent's files.
I look forward to your prompt communication.
Sincerely,
ael T. Cailahan,
MTC/sll
cc: Mr. Bradley Ledford, via U.S. Mail
Mr. David Ledford, via Email

AO 00144
fvîiek Ctnliahsn ^midt^michcallslisniAw.ooi
e: Cawthorn v Ledford, et al Cawthom v Ledford; Claim No.56-00723-14
ck Callahan <mick@mickcallahanlaw.cxjni> Thu,Aug 21,2014 at 3:48 F

•: McLean.PameIa@aolns.com
Dear Ms. McLean:
I am personal counsel for Auto Owners for Bradley Ledford. I just got involved In this matter and have acquired informatior
Tom the Ledfords and from your assigned counsel for my client, Jamie Moses. I have attached an email that I sent to Mr. Orr
ihinking he was Auto Owners counsel when I first got involved, and his response. He advised me that he represents the
/ehicle owner as assigned counsel so I would like you to consider the attached letter as addressed to you as Auto Owners
'epresentative.
^lease provide the information and documents requested in my letter to Mr. Orr promptly so that 1 can be fully informed as to
/vhat has transpired to date.
Ms. Moses has also informed me that the Plaintiff's counsel has In fact now rejected the tender of policy limits so that my
client is potentially exposed to amounts In excess of Auto Owners policy limits. I have also recleved documentation since that
etter was written to Mr. Orr that Mr. David Ledford made inquiry about the vehicle salvage from Arô Owners agent and was
:old that the vehicle could be disposed of. Both of these matters concern me as there may be spoliation of evidence
necessary to defend my client or to seek shared legal responsibility and there may have been a real chance at settlement of
ills claim against Brad within policy limits that was not pursued or was blown by Auto Owners by ifs failure to be proactive m
settling the claim.
Thanks for your prompt attention to these matters.

Sincerely, Mick Callahan
Michael T.Callahan,Attorney atLaw

29351st Avenue North,Suite 2
3t. Petersburg,FL 33713
Phone: 727-209-1504
Fax:727-502-9621
tVebsite: www.raickcallahanlaw.com
Confiden tial: This e-mail containsa communication protected by the attorney-client privilege or constitutes work product, ifyou
jo notexpectsuch a communication please delete this message withoutreading it or any attachmentand then notify the sendei of
i/iis inadvertent delivery.
Re Cawthorn v Ledford et al.msg

□
^ 33K
ck Callahan <mick@mickcallahanlaw.com> Th"' ^"9

■: Joni Canterbury <joni@adventuremotorhQmes.net>, John Holcomb <jholcomb@hwhlaw.com>
^lease note my communication to Auto Owners. Mick
Quoted text hidden]
pi Re Cawthorn v Ledford et al.msg

^ 33K

AO 00145
S/24/2014 P-îahan Law Mail - Coverage/Presurt Questions - Cawtiv^ne v. Ledford
Coverage/Presuit Questions - Cawthorne v. Ledford

Tue, Sep 16, 2014 at 4:06 PM
To-S'n'hlSw®arcom°^
<mick@mickcallahanlaw.com>
John and Mick:
You both asked about who your contact should be with at Auto-Owners regarding coverage presuit
questions, of which I cannot answer or address. Those questioi^ should be directed to Mehnda Pittaian with
Auto-Owners Insurance Company. Her telephone number is(517) 323-1201, ext. 6251.
Thank you.
-Mike
Michael Fox Orr,Esquire
DAWSON I ORR
The Bank of America Tower
50 North Laura Street
Suite 1675
Jacksonville, Florida 32202
(904)358-8300(p)
(904)358-8303 (f)
info@dawsonorr.com
www.dawsonorr.com
Melinda Pitman
Tuesday, May 9 201"7
, StPinhPt-««e'r RPK
Please corisider the environment before printhig this e-mail.
B-rwatl Ponfidenttalitv Notice
^..i/M/n/'>Mi=7Aiir=Rhf?la1dh32&vi0W=Dt&search=:inbox&th=1488O13O©O1524d6&slml=1488O13OeO1524d6&siml=148a852bfd9... 1/3
9/24/2014 Câhan Law Mail - Coverage/Presult Questions - Cawthome v. Ledford

This e-m^ transmission
^nis trsnsiiussiwi and
oiiu any
any documents. -iS or previous e-mad messages attached to it, are coi ntial and are protected
Qocuineiitb, ^9\jl . •by.the attorney
jj
cUent privaege and/or work product doctrine.If you are not the intended recipient, or a person responsible for delivering it to the mtended
/'^^^cipient,you are hereby notified that any review, disclosure,copying,dissemination, distribution or use of any of the information contame ,or
tached to this e-rnaiJ transmission is STRICTLY PROHIBITED.If you have received this transmission in error, please immediately notify me by
forwarding this e-mail to mfo^dawsonorr.com,or by telephone at(904)358-8300 and then delete the message and its attachments from your
computer.
Tax Advice Pisdosnre;
Pursuant to the requirements of Internal Revenue Service Circular 230, we advise you that any federal tax advice contained in this commi^cation
(including any attachments)is not intended or written to be used,and cannot be used,for the purpose of:(1)avoiding penalties that may e
imposed under the Internal Revenue Code or(2)promoting, marketing or recommending to another party any transaction or matter addressed in
this communication.
Mick Calfahan <mick@mickcallahanlaw.com> Tue, Sep16,2014 at 7:23 PM

To: Michael Fox Orr <mfo(Sdawsonorr,com>
Thanks, Mike. Do you have an address or email for her? M

[Quoted text hidden]
Michael T.Callahan, Attorney at Law

2935 1st Avenue North, Suite 2
St. Petersburg, FL 33713
one: 727-209-1504
7ax: 727-502-9621
E-mail: miclc(®Tnickcallahanlaw.com
Website: www.mickcallahanlaw.cora
Confidential! This e-mail contains a communication protected by the attorney-client privilege or constitutes work
product Ifyou do not expectsuch a communication please delete this message without reading it or any attachment
and then notify the sender ofthis inadvertent delivery.
Michael Fox Orr <mfo@dawsonorr.com> Wed,Sep 24, 2014 at 11:23 AM

To: Mick Callahan <mlck(gmickcallahanlaw.com>
Co:"john.holcomb@hwhlaw.com" <john.holGomb@hwhlaw,com>
Yes. Her email is pitman.melinda@aoins.Com.
From: Mick Callahan [mallto:mick(§)mlckcallahanlaw.com]

Sent: Tuesday, September 16, 2014 7:24 PM
To; Michael Fox Orr
Subject: Re: Coverage/Presuit Questions - Cawthorne v. Ledford
'Ick Callahan <mick@mickcallahanlaw.com> Wed, Sep 24,2014 at 11:30 AM

.0:"michael tcailahan" <Mick@mickcailahaniaw.com>
iinniii=9Aiif=fihf9aidb32&view=Dt&search=inbox&th=148801 SOeOI524d8&s[ml=148801SOeOI524d6&siml=148a852bfd9... 2/3

aioAnMA OUahan Law Mail - Coverage/Presuit Questions - Cawthocne v. Ledford

• . - . „, ^ Wed,Sap 24.2014 at 11:32 AM
Mick Callahan <mick@mickcallahaj .\w.com>
^Jo: Michael Fox Orr <mfo@dawsonorr.com>, John Hoicomb <jholcomb@hwhla .
Vhat office is she physically located in and what is the mailing address? Thanks. M
^ . rr*~i 7
Mick Callahan <mick@mickca!iahanlaw.com> ^ """" Wed,Sep 24,2014 at 11:34 AM
To: Michael Fox Orr <mfo@dawsonorr.com>. John Hoicomb <]holcomb@hwhlaw.com
Did you acquire Information regarding the call to Auto Owners David Bedford related to us on the subject of
dIspLltlon of the vehicle? If so, please provide details to me when you recewe it. Thanks. Mick
[Quoted text hidden)
Wed,Sep 24,2014 at 11:41 AM
6101 Anacapri Blvd.

Lansingy MI48917
From; MickCallahan [maiito:mick@mickcailahanlaw.com]

Sent: Wednesday, September 24, 2014 11:33 AM
To: Michael Fox Orr; John Hoicomb
Puoted text hidden]
"""= . . , 77 i T' Wed,Sep 24,2014 at 12:59 PM

Mick Callahan <mick@mickcaliahanlaw.com> -u i r.nm>
To: Michael Fox Orr <mfo@dawsonorr.com>, John Hoicomb <jholcomb@hwhlaw.com
Thanks, Mike. Do you know if Auto Owners has had anyone in Florida working on the claim since it was
reported? M
Wed,Sep 24. 2014 at 1:25 PM

Michael Fox Orr <mfo@dawsonorr.com>
To: Mick Callahan <mick@mickcallahanlaw.com>
Cc: John Hoicomb <jholcomb@hwhiaw,com>
Pamela McClane.
Sent from my iPhone

=RhB.,1db32&vi8W=pt&S6andl=lnbox&th=14880130e01524<i6&slnnl=14880130e01624<i6&8lml=1483852l)fa9... 3«
.into,itsOAIIy;
Pitman, Melinda

Sent: Wednesday, September 24,2014 9:50 AM
To: Anderson, Reggie
Subject: FW: 56-723-2014/ Bob Ledford's RV 8i Marine
Reggie
Have you learned anything a bout the salvage in this matter? We are under the gun to respond to personal counsel
for the Insured. I am headed into a meeting but would you have time to chat after lunch?
Melinda A. Pitman, Attorney

(517)323-1201, ext. 6251
Pitman.MellndaOaoins.com

Subject: 56-723-2014/ Bob Ledford's RV & Marine
Reggie
Would you refresh your memory about this claim and then give me a call when you have a minute. I am specifically
looking for information about the insured's vehicle and the salvage and any information you may have about that
Melinda A. Pitman, Attomey
(517)323-1201, ext. 6251
Pitm3n.Mellnda@aoins.com
Melinda Pitman
Tuesday, May 9,201?
_ljanrj= RPR

AO 00537
EROM: MeUnda<Pitman^MeIiiida@aoifis.ccymi^
TO: Legal.ImageRight.Files
SENT: Wednesday, September 24, 2014 3:44:23.PM East^Dayli^t Tiine
SUBJECT: FW> 56-723-2014/ Bob Ledford's R,¥ & Marine
File
From: Anderson, Reggie

Sent: Wednesday,September 24, 2014 10:03 AM
To: Pitman, Meiinda
Subject: RE: 56-723-2014/ Bob Ledford's RV & Marine:
Hey Meiinda,
Sorry for the delay in my response but I've been trying to play catch up since I took vacation. Just give me a call.
Regarding the salvage we(Auto Owners)did not inspect or pay any damages to our insured's vehicle because he did not
have collision coverage. Not sure where the salvage/insured vehicle status is at present. Hopefully we can speak after
your meeting. Thanks
Auto-Owners Insurance
Greenvilie Claims Branch
854-675-0811 H 8054
From: Pitman, Melincia

Sent: Wednesday,September 24, 2014 9:50 AM
Subject: fW; 55-7^r2pl4/.Bpt? Ledford's Maripe
Reggie
Have you learned anything about the salvageJn this matter? We are under the gun to respond to personal counsel for
tbfe ihsufe^. I. aifi headed into a imeetihg but.wpuld ypu have time to chat after Itinch?
Meiinda Ax Pitman, Attorney
Auto-Owners Insurance Company"
(517) 323^1201, ext. 6251
Pitman.MelindaOaoins.com
From; Pitman, Meiinda

sent: Tuesday,,Septembep'16, 2014 4:02 PM-
To: And^^n, Reggie
Subject: 56-723-2014/ Bob Ledlbrd's RV 81 Marine
Reggie
Would you refresh your memory about this claim and then give me a call when you have a minute. I am specifically
Ipoking for information about the insured's vehicle and the salvage and any iRfprmatlon ypu may have about that.
Meiinda.A. Pitman,Attorney
Auto-0\ft/riers Insurance Company
(517) 323-1201, ext. 6251
Pitman.Melinda(5?aoins.com PLF EXHIBIT 34
Meiinda Pitman
Tuesday, May 9,2017
i anro PPR

AO 00536
ITLOM:Pitrnjm,.Melinda<PitmanMelinda(ôins.com>
TO: LegsiLlmageRighLPiles;
SENT: Friday, September 26,2014 12:25:38 EM Eastern Dayli^t tirn^
SUBJECT: FW:.Cawdioni v. LedfOTd^ et al.
ATTACHMENTS: CCF092520l4.pdf;
pile
55-723-2014 and 42-1134-2014
From: Sherri LaFerrara [mailto:sherri@mickcallahanlaw.com]

Sent: Thursday, September 25, 2014 9:51 AM
To; Pitman, Melinda
Subject: Cawthorn v. Ledford, et al.
Dear Ms,Pitman:
In connection with the above-referenced matter,^ I have attached correspondence from Mr. Callahan for your
convenience. A copy is forthcoming in the U.S. Mail, Please contact this office should you have any questipris. Thank
you.
Sherri L.LaFerrara -Legal Assistant

2935 First Ayenue North, Suite 2
St. Petersburg, FL 33713
Phone: (727)209-1504
Fax: (727)502-9621
.Froail: sherri@jTiickcallahaiilaw.com
Website; www.mickcailahaalaw.com.
PLF EXHIBIT 35
Melinda Pitman
Tuesday, May 9,2017
.1 an>-o Qtoinhcwttcor OPR flSP-

AO 00136
r^
Michael T. Callahan
AXtQR3Ê:Y AT LAW
itiCHAEL 1! GALIAHAN 29354Âvtot^ tiLEPHON*E {727) 209-1504
Aoicirttb iHtliAiig FtoRTOA

StipB It jBiCSlMfljE ^277502-9621
Gerxihed Circuit Civil Mediator ^JPETERSBtlRG. RjORinA 33713 MICJi^SMlCSX^^
\C3SrWliid^CKCALL«lAA%AtCC^^
S^teamber 25,2bl4
VIA EMAIL: PITTIV1AN.MELINDA@A01NS.COM
Ms. Meiinda Pittman

Auto-Ovyners Insurance Company
6101 Anacaipri Blvd.
Lansing,MI 48917
Re* Cawthom V. Ledford, et al.

Cl^No.: 56-00723-14
jDear Ms.Pittman:
i represent Bradley Ledfdrd, the driver ofyour insured vehicle in the claim noted above.
He and Ms Mther's company were sued by MadisOtt Catwthom,the guest passenger, as a result of
au accidentin Volusia County,Florida. John Holcomb represents Bob Ledford'sRV and Marine,
die nafitjed insured and owner ofthe vehicle. Both he and I have been attempting to ascertain the
piop^r person to COrnmunicate with regarding questions our clients have had regarding Auto
Owners handling of this case prior to sUit. Your assigned Counsel, Michael Orr, referred me to
you two weeks ago. I telephoned yoitf office With n detailed message about who 1 ami Uiid the
claim number and made some specificrequests of you. You never returned my call.
I:hnve attached the emails and letters previously sent to yOiff>assigned counsel and to Mrs^
McLean to whom we were directed. Ireceived no response froni her either. Mr,,David Ledford,
theowner ofBob Ledford's RV and Marine and his son,Bradley, who is a minor,and his custociial
mother, Beth, simply cannot understand how they can be treated s£> shabbily by their casualty
hisutancecarrier when they have been fiilly cooperative with everything asked ofthem to date and
when Mr. David Ledford has provided so much voluntary help, documentation, photographs,
statements and meetings with your assiêd counsel to assist with the defense offile claim, iiow
.Ihwsuit.
The fecftsth^jiiaVe been able to develop seem to indicatetoatfironi the time ofthe accident
Oh April 3,2014,xmtil toe end ofthe first week ofAugust,Auto-Owners made no offer ofits policy
limits to Joe ICalbac the attorney representing toe Cawthom family. I have also now leamed frOm
yOuf own attorneys assigned to represent the Ledfords toat Mt. Hialbac rejected the offer as

AO 00137
liiitiniely that the lawsuit could have been settled in its endrelyhad policy liim^fe been Offered
e^llet. Iftrue,this concerns the Ledfords greatly.
:I have previously requested jn the correspohiiJeiice ^ched to ttiiis letter the names and
î>iOs of written communications pf eyeiypne at Auto-Owners who communicated with the
Ledfords, Mr.Kalbac or others regarding anjlhing dealing with this accident from die date it. was
reported to the filing ofthe lawsuit. That would include a copy ofyour claims file which my client
is entitled to see and a copy ofall letters and emails genemted on behalf of the Ledfords. I want
cêsofthose coimnunications now.
My client is also concemed that the vehicle was disposed ofand issues have arisen in this
Case iâhding evidence ofdamages to the vehicle which may bear directly on the cause and extent
ofthe hynries to the guest passenger, Mr. Cawthom. Mr.David Ledford was told by the company
which held the damaged vehicle that he could not -Answer their inquiry regarding holding die
savage Md that they should contact Auto-owners which they apparently did. The vehicle w^s not
retained. I waiit to ôw what evidence you have in your files regarding disposition ofthe vehicle
md 1 wahtcopies ofeverything relating to it
The Ledfords certainly hope that you cm respond finally to my requests for information.
MTC/sII
End.
cc: JohttHolcomb,Esq. tOl E Kennedy Blvdl,#3700,Tampa,FL 33602
hir. David Ledford,421 Watercrest Court,Inman,SG 29349
Messf. Bradley Ledford c/o Mrs. Beth Ledford, 18 Brooks Meadow Ln.,Arden,SG 28704

AO 00138
AUTO-OWNERS INSURANCE COMPANY ^ ^

AUTO-OWNERS LIFE INSURANCE COMPANY W >
uAuto-OwnersImuranee
V. Life Home Car Business
7}\pypPfb6î(y^'^-
P.O. BOX 30660; LANSING, MICHIGAN 48009-8.160 • 517-323-1200

FAX 5.17-323-879G
.VVWW.AUTaOWNERS.C,6M
Seplejnber 26, 20.H,
Via regular inail and e-niail: inick@inickcnilahniiln\v.com
Michael T. Cal.lajinn, Esq,

2935 r' Aveiiue Noi tliyS'iiite 2
St. Petersburg,,Florida 33'713
-Re: Cawthorn v. Ledford"

qiainiNp. 56-00723-14
Dear'Mr. Callaimn:
Thank yoii for your letter dated Septeihber 25,2014.

As you know, AiitpÔwivers 1ms tendered; its inilli'oit p.Olicy limifs to. the Claiinant MadisoniG.atnhgilv >
aiid/dr liis.,repre'sdnrativcs. We believe that-Auto-Owners tendered:those liini.ts correctly and timely, Auto-
.Owiiers. is also' providing;:Bradley-Ledford ^vitlv-a deifen'se in the la\vsuil against hiin;, tyithout-aity
feser\m.tioii,Of f.ighls- AiiJo-Qwhers:ims Vetaihed-the;se'iyiceS bf defehse 'dttoin),ey Mpsjes, to defenii;
Biradley,. wiiQhir l believe: you have spoken with.. Auto-Owners will continue to vigorously defend your-
clienf and oiii-'ih§tired and t.O [.riE)ke every attenipf to reSolye tl.te diailii within policy limits,
III regaT.d 16 your request for our claini investigation filej i believe your client Bradley. Ledford .and his.
fatlre'r, Davrd Ledford^ have copies:of Ilieir cpniiiiitnic^tions With Autp-Owners. Hpwe.yeiv ifthey did not
reteiin copies, .1 will be glad to seiid additrdiVa! copies to you. I ;alsb ain ehelOsing: copies of m
coniimmicntions to 'Madison Gawthoni .and/or his. representatives about tlie payment of yoni .clients
poiicy limits, The mst of our claiin file is a confideiitial busiiiess record.
As to the condition and location of tlie damaged velucle, I have no inforninlion about tliat, Tiie insiued did
nOl buy any collision coverage from Atilp-Ownci'S flnd there was nO need for Atito-Owneis to apprtilse
and purchase the salvage. The question of what to do with the wrecked vehicle would thus have been at
the owner's discretion.
Please let me know If we can be of 0113' fuiiher assistance.
Vciy truly yours,

AUTO-OWNERS INSURANCE COMPANY
Melinda A. Pitman
Attpmey
itlrecuiinl: (5I7)W-I20l exi. 62il
MAP/smc
Enc.
Melinda Pitman
- Serving' Onr PoUcyhohlfrs and Aiicnlsfor More Than 90 KtYZ/.v -
McLean, Pamela

Senl: Wednesday,June 11, 2014 2:17 PM
To:- 'Roger'
Subject: RE: Bob Ledford's RV
There Is $3 million in coverage.
From: Roger rmallto;rDzm777@aol.com1

Sent: Wednesday, June 11,2014 2:08 PM
To: McLean, Pamela
Subject: Re: Bob Ledford's RV
How much would the check be for?
Sent from my iPhone

Roger Cawlhorn
On Jun 11,2014,at 12:59 PM,"McLean,Pamela" <McLean.Pamela@aoins.com> wrote;

The payment that we make would be In a lumpsum for a release of our insured. It would be for you to
disperse. The payment wouid be made to your son for use at his discretion.
From: Roger fmalito;rpzm777@aol.com1

sent: Wednesday,June 11,201411:58 AM
To: McLean, Pamela
Subject: Re; Bob Ledford's RV
I see that this letter states"we will be able to bring the insurance portion of this matter to a conclusion.
Not sure what is meant by that. My son will have bills from other places, doctors,surgeons, therapist
and others.from Florida and here In Georgia. Also for his long term care for years to come.
So I would think there will be a lot more bills to be paid.
Again,the conclusion part of what?
Thank you.
Sent from my IPhone

Roger Cawthorn
On Jun 11,2014, at 10:42 AM,"McLean,Pamela" <McLean.Pameia(5)aoins.com> wrote:

it was a pleasure speaking with you this morning regarding your son's
accident. Attached Is the letter we discussed with the medical authorlrallon Included.
Upon receipt of the signed release, I will obtain the records from the hospital so that we
can bring this matter to a conclusion.
AS I said, please call me with any questions. My cell phone number is(352)208-8574.
Pamela T. McLean,CPCU
Ocala Branch Claims
(800)437-6164x8406
Auto-Owners Insurance Company j

P.O. Box 3200 I
Ocala, FL 34478 i
(
1
<Attachment.pdf> !
McLean, Pamela
From; McLean, Pamela

Sent: Monday,June 30,2014 1:43 PM
To: rpzm777@aol.com
Subject: 56-00723-14 Bob Ledford's RV & Marine,Inc.
Just wanted to send you a cjuick note regarding the medical authorization that I sent to you. As soon as I receive that
will be able to get the medical records from Halifax Medical Center.
I hope your son Is doing well and continues to Improve.

Ocala Branch Claims
(800)437-6164x8406

P.O. Box 3200
Ocala, FL 34478
AolvUwiiei^ liiiutatKt (ompctny

Aotu-Ur/iicii(Uc Insonmc;(onitiaa/
lloitiu'Uniioti liiiuiitiK# (ompnay
Unnui) liitDtunco (ompoiiy
^ûtO'OwnersInsurance
rio|ioily'l)i«ieif (iiiUiiiiKo (oui|titny Life i lome Car Business
Suuthorii'Ouavit Iiisuioiko (4ni|icin]f
P.O. Box 3200

Ocnin,FL 3«1«J78
PHONE(352)873-9388
Toll Fi'cc(800)437-6164
F-fVX (352)873-9370
Augiiil 7,201'I
Sen! via Fuosimllo willioiil AUaclyneiUs

Regular Mnll wltli Allncliinenls
Joseph J. Knlbeo, Ji'.

Colson Hicks Eicisoii
255 Alhnmbrn CirQlc PH
Minnii, FL 3313^
Ro: Our Jusured Bob l.cdford's RV & Marine,Inc.

Your Client David Ma<li3on Cnwihom
Dale of Loss 04/03/14
Dear Mr. Knlboo:
Byway ofinlroduotion, my name is Pamela McLean aud 1 am linndlmg Ihe msiirauce olaitn on
behalfofBob Ledford's RY & Marine,Inc. and Bradley Ledford for Ihe iiyuries sustained by
your client, As you are likely aware, we have relayed our desire to tender our insured s liability
coverage to your oliont upon receipt of any dociunentalion ot Ihe Injuries that ho sustained In(he
accident ontiio above mentioned date.
While we have not yel received any medical records, we did mcenlly receive a notice oflien
from Mr, Cawlhorn's hoaltli insurance caiTicr. Wo liave altachod a copy ofthat notice that was
sent to us via facsimilo on July 31,2013, After receiving this notice, wo do feel that we have the
documonlntion ncccs.snry to lender the in.snrcdLs coverage to your oliont. That ooveiago Is in the
atuoimt of$l iniilioii under a garngo liability policy and $2 million available under their
umbrella. We have ottnclied two payments roprcsonling tho.se limits as well as a copy ofIhe
We are offering the coverage In exchange for a release ol the named insured and the diivei ol the
vehicle, Brndloy Ledford. Please contact me at your convenience so that we may reach an
agieomcnt on.a mutually acceptable release.
Sorviiiii Our I'olityhohlors mid Ayenls for More Tlimi 95 Yciirs

Should you hnvo any questions or wish (o discuss any nspcol ofthis clnini, picas© do not iiesitate
to contact mo.
unela McLean, CPGU,(Rxt. 8406)

Ocala Branch Clnim.s
Co; Michael On*

Attorney at Uiw j
50 N. Laura Street, Ste. 1675 •
Jacksonvillo, FL 32202
Co; Jomlc Moses

Attorney at Law
P.O. Boa 3753
Orlando, FL 32801
^GM:Pitniarii MeUnda<Pitmaii.Meliiida@aoins.com>
TO; Legal.ImageRightFiles
SEOT:Tuesday,September 3,0, 2014 5:37^17 PM'^sterri Dayligbt Time;
SUBIEGT: FW:Cawthomv; Ledford, et al.
ATTACHMENTS:Lfr Pimiaii 9.-30-14.p<if;
File 56-723-2014 and 42-1134-2014
From; Sherri LaFerrara [mailto:shern@rnickcallahanlaw.com]

To; PitmarT, Melihda
Cc: david@adventuremotorhom^.net; jhoIcomb@hwhlaw.c6rh; Beth.Iedford@aGaltQn.drg
Subject; Cawthom v. Ledford, et al.
Ms. Pitman;
In conriectipn with the above-referenced matter, please find the attached correspondence. Sfipuld Vd-U have any-
questions, please do not hesitate to contact this office. Thank you.
Sherri L. LaFeirara -Legal Assistant

2935 First Avenue North, Suite 2>
St..Petersburg,FL 33713:
Phone: (727)209-1504
Fax: (727)502-9621
Bmaii: sheni(Am ickeallahan law:,com
Website: vvwv.mickcallahanlaw.com
ri PLF EXHIBIT 37
Melinda Pitman
_l anrp PPR

AO 00132
MICHAEL T, CALLAHM<1
4XTORNEY AT LAW
2935. AVENUE Njotrtt TCLEFHONE 1/27) 209-1504

• MiCttAEL t <2/JXmAlf fiyCSiStitE (727) 502-9621
Suite 'i\
AOMITTED IN UTAH:FtORlDA; MICE30WCKCAlXMLA>nj^
CERTIFIED Circuit Civil Mîator
;^.iPEtER®V^ FtORlUA33713
WWVtfMICKCALtAHAhnAV.COM
geînijfer 304 2014
VIA EMAIL: PTtKIAN MEI 1NnA@AQINS.COM

MSi MelmdaPitman
Auto-Oîiers Insurance Company
6t01 Anacapri iBivd.
longing,MI 48917
Rei CawliiQmyv Wford,etal.

Policy NumEen 48-901-965-00
Claim No.: 56-00723-14
Eiear M^,Pitman:
lhank you for yodr letfet of §^teihl?et 2.% 2014- I will 5g^0nd I? each of. the
ijêsenlatioiis made in your letter.
I am aware of wiurse that Auto-Chsmefs offered its policy limits for the fifgt time m this
case onÂugust 7, 2014. The issue for ihy client is why did it take your company
apftttefiom the ofdie awideht to do so,and why did you not involve Bradley Leôrd md
Jus IJMMts In the process ovisf that period of tirne? Auto-Owners has been m tot^ cpntrofo e
ihv^gation and negotiation of Ms qlmm since it happened. My cUent is a minor and totaUy
dependent upon your keeping his parents informed and on Auto-Ownersjudgment and use or
care and diligence in handling the matter.
This is a matter where prompt ^d immediate ifiye&tigatibtt of pp^ntig-da^

wouldtee liiformed your company ofthe extent ofthe daiiiagos and pie potmlial 9rtuy
client tin: his guest passenger who was asleep vvhert the accident occuired. If Auto-Owners was
not irffomied of the daimges, why did it fail to make proper inquiry? If Aiito-OMêm tew of
the terrible damages to Madison Cawthom, why did it delay in Offering,the pohcy imi •
receiwd no explanation Of why Auto-Owners waited over four months to make m offer Of
policy limits other than your statement that "we believe Auto-0\\mers tendered Jhpge te
tnneiy and coirectly,'' Was diere sOme reasonable cause for the delay? If so, I would like aU:
^planation.

AO 00133
If ah earlier and proh^t inyesdgsôn md tender of limits would ^yo resulted in n

setdenient withbht erasing my client and his lather's Gompany to liability th ex^s o t e
ijQllcy limits, then yoiir '%eUef' that Auto-o\\Tiers tenderly timely is of Ijttle cOmfort 10 the
Ledfords, tir to Mr. Ledford's corhpahy, or to my client, Bradley, who may have to Shfrer an
excessjudgment
riave madoiticiuiry of Mr,Kalbac regarding Auto-Owners knowledge ofthe iiyunes md

liabiliW circumstances, and of eonimunications made by Auto-Owners with his clients,
have asked him to provide me with whatever infoimation he feels he can divulge in that regard.
If AtUÔwners refuses tO divulge vdiaf went on during those four niOhths, then perhaps
Plaintift's attorney will do so.
I haye asked your company to inforrh me of when and how you advised ihy client
Btadley orto partats, David and Beth Ledford, of your efforts to initiate settlement and_yon
have given me lidtldBg but the offer of August 7 after the matter was already m suiL I have
asked you to provide letters, emails or diary entries which would show what was done on behalt
of my client and you l^ve responded that the claim file niaterials are a confidential busmess
record" which Auto-Owners is unwilling tO produce to die.v^y persons Oh whose behatf these
gcfivities were undertaken. 1 do want you to produce iliose materials and change your position as
it seems incredible to the that you would want to conceal them from the Ledfords.
J would like you to di^lose specificaily'- WliM cpmmunicatioiiS and discussions your
company had with Matfison Cawfoom's fonfily, and ultimately with Mr.KMbac who represents
hiri Madison Cawthom,up to the time he rejected the policy limits to settle his client's case. I
will also take you up on your offer to provide me ALL communications from Auto-Owners to
the Ledfords from the date ofthe accident to August 7,7014,
I am in Gonstmt commuhicatioii with the attomeys whom you selected to represent the
defendants, Bob Ledford's RV and Marine, Inc. and Bradley Ledford, Michael Orr ^d Jame
Moses, respectively, aiid we have no problems comraumcating with each otheri,nor have they
beSh in any way tracooperafive in!the defense of foO;cdahn- Mr. David Ledford, Mrs. Beth
Ledfoid and their son Bradley have all been fully cooperative and we all hope thatthey somehow
areâble to resolve this case still within the available policy limits. Butjust because the attorneys
are how forced to m?ke evmy ^fiforf to defend the case to attempt to resolve policy
limits doas not mean fiiat Auto^Qwners made arty real effort to settle the case before smt within
poliicly limits.
Finally, I did hOt ask you to tell me tl^them was hb heed for^ Aiô-Owpots to appraise
the vfehicle as they did not have collision bh it, or whether it was îat the oilers
discretions^ to dispose of the vehicle; Thi is hot the issue. The question is did anyone at Ahto-
Owners corhmunicate with the salvage yard- mid indicate to it that tlie vehicle could be disjiosed
of. Would you please advise me for my client's benefit specifically aS to whether this was done
f^S

AO 00134
or i&dt bj Atito-Owners ELgerit or employee? Thank you for youir inquiry and re^jonses to
the^ qt^pm
Sincerely,
Michael T. Callahan
MTG/sll
cci Mr.David Ledfofd(m pn^l)
john Holcomb,Esq.(via email)
Beth Ledford (via U.S. Mail)

AO 00135
t JB
Effective Date
D PLF EXHIBIT 56
^ûto-Owners Mnsuran^ Pamela McLean
Life Home Car Business
Thursday, May 11, 2017
Lance Steindesser RPR CSR
Cavvthorn v. Auto Owners

CONFIDENTIAL AO-CHG 00001
AJl States
AIJTOMOBII.E CLAIMS
Automobile Claims
Claim Handling Guidelines
These guidelines ^ply to all automobile files:
• Gbmmunication with insureds and third parties should be documented in each file.
• !^0T will be used as the contact record for all imaged files. Glmm ^spciates should indicate whether
the accident was at fault and ifa loss cauSe code is applicable.
> A claim file should include an eyaluation ofcbvefages and shbuld docuineiit that relevant coverages
have been explained.
• Whether a lienhblder exists should be noted on the loss report or within the file.
• All unpaid bills should include the reason for not having been paid.
• When a cheek is voided or stopped,,the claims system should be noted,accbrdihgly on IPDS,
• Files should clearly reflect the disposition,ofall salvage; Iflefi with the owner,the value ofthe salvage
should be indicated Disposition ofsalvage is expected to conform to applicable state statutes and
company pfOcediires.
• On ^y file where coverage is.subject to a co-insurance clause, specific figures and values should be
shown in the file when the loss is in excess of;10% ofthe limit ofliability or $10,000, whicheveris less.
Losses ofproperty at lower values may warrant calculation and application ofcoinsurUnce,
• Underwriting recommendations should be sent on all claiins where there is an increase in hazard, or any
adverse condition.
• If an appraisal is made, and a value given,deviation fiona that amount should be explained in detail by
the claim associate.
• The "gross amount ofloss" is the estimated loss, before any depreciation or deductible is applied.
• The preferred method for handling automobile claims between the amounts of$1,500 and $3,500 is desk
review. There are instances when an inspection on claims below $3,50O may be needed. Xhese
instances should have file documentation fm the decision. For losses greater than $3,500, an inspection
by an In HoUse Appraiser Or Independent Appraiser shouldtê place. Situations where an inspection is
not advisable should be documented.
• Ifthe vehicle is determined to be a total loss, the branch will use a total loss valuation tool to determine
the actual cash value ofthe vehicle, unless claim circumstances dictate the need for using another spmce
to determine the actual cash value.
• The Mitchell Total Loss Summary page and the Total Loss Payment Authorization Form 18967(11^13)
shoidd be put into the claim file. The amount shown on these documents should match tlie amount pm4
to the vehicle owner. Title and other fees are to be shown on the form in the proper area mid reflected in
the amount paid.
• All automobile total losses require that the vehicle owner furnish AutoÔwners with a clear title ifAutor
Owners takes possession ofthe salvage.
• Parties which may have been injured should be contacted to determine liability, and the extentofany
injuries sustained.
• Total loss vehicles require an (Mitry in KART to ensure compliance with federal statute.
• Any lienholder named on the policy at the time Ofloss must be included On any check;(a)in settlement
ofa total loss,and(b)any cash settlement.
• Origin and cause investigations may be considered on total loss fires. A recorded statement should be
considered and completed if warranted.
CONFIDENTIAL
• Claim associates:should identify whether an ISO ClaimSearch.Match Report was received on the claim.
If yes, he/she should descrilDe whether the matches are releyant to the claim or not and why. KKOT is
the preferred method to document these observations. Claims inquiries should be conducted, as needed,
and the results documented. Ifrelevant tnatches are found,the matches should be printed for the file.
The claim associate should describe what questions suggest additional investigation is needed.
• Any claim which mayinvolve possible red flags or questions should be discussed with branch
management Ifapplicable,the claim shoddbe referred to the Special Investigation Unit(SIU)using
their referral form. SIU will advise if addiliOnal.reporting is heeded to Home Office Claims. The
questions needing additional investigation:should be identified an4recorded staternents Considered
CONFIDENTIAL
All States
AUTOMOBILE CLAIMS
Claims Handling Issues
Collision and Property Damage
When making payinent on a cpflisiph loss,the inSured's name and body shop and/Or lienholder should be,on
the check.If paying only the lienholder on a total loss, it must be with the knowledge and consent ofthe
owner. It is not suggested or recommended thatâuthorization to pay directly is obtained.
The check and a copy ofthe estimate or appraisal are to be forwarded to the insured SO they may have the
check and a copy ofthe estimate or appraisal when receiving payment for the repairs to the vehicle. A
supplemental payment for repairs on an irisured's vehicle thatexceeds 10% ofthe original repair cost should
have both the insured's name and body shop on the check. A copy ofthe supplemental appraisal should be
pfovidedtO the customer and the custoiner should authorize the supplemental repairs with the repait fecility.
Ifa claim associate is Settling a total loss,with an insured and there is a lienholder listed on the policy^, the
lienholdeds;name should be placed oh the check Ifthe insured provides a title which shows that aU
lienholders have been released, it is not necessary to include them on the check. Sometimes the lienholder
oil the policy is different than thelienholder Oil the title. The claim associate should obtain docuiuentation
that the lienholder on the policy has released their lien. Ifnot, their name must be on the check. It is the
insuted's responsibility to have henholder's names mmoved from the policies as changes occur, it is
permissible to issue two payments,one to the insured and lienholder, orjust the lienholder ifthat is the
owner's preference, for the confirmed loan balance. A second payment can be made tojust the vehicle
owner for their equity in the vehicle.
Prior to making settlement on a total loss,the claim associate should document who owns the vehicle as it
may differ from the insured or claimant. A potential problem in selling salvage is title transfer. This can be
eliminated by documenting ownership prior to making settlement. Ifthe yehicle is titled to someone other
than the insured or claimant arid Auto-OwhefS:has liability for the loss to the Vehicle,it is the insured or
claimant's responsibility to providethe claim associate wilh avenues to obtain a title to the automobile prior
to making payihent Such situations may require the narried insured Or claimant, the titled Owner arid ariy
herihplders to appear on the check,
it is also important to determine the type oftitle on the vehicle, A"salvage" or "flood" brand on the title
may reduce the market value ofthe vehicle. This needs to be known prior to settlement ofthe claim so this
can be taken into consideratiori when settling the claim. TTiis should be discussed with the owner prior to
making settlement offers^ Ifthere are questions, a copy ofthe title from the owner should be requested prior
to settlement
When settlhig a property damage claims the check should be mtade payable to the claimant. A copy ofthe
estimate or appraisal should be provided to the claimant. Only include the body shop, as a payee^ with the
approval ofthe claimarit. When makingpayment for a supplemental claim ori a claimant vehicle, the
claimant's name should be included on the check It is advantageous for the claim associate to explain to the
automobile appraisers in advance how Auto-Owners handles automobile repair Supplemental payments. A
copy ofthe original appraisal or supplement should accompany the payment. In some instances a claim
associate may conclude a release is appropriate arid should be Obtained,
When a claim involves a total loss on a high-value or specialty car, it is frequently (flfiQcult to obtain a
qualified appraiser to establish an accurate value ofthe vehicle, Mitchell Total Loss Valuation is the
primary source to determine the values ofthese vehicles. Ifneed be,the internet can also be utilized. The
CONFIDENTIAL
Auto physical Damage Departaeqt in Hom^ Office Claims has access to Hempiihgs which may also be
used as a resource. Hemmings,a magazine that is published monthly,has been a source for iSnding parts,
qualified appraisers and dealers for these tês of vehicles.
CONFIDENTIAL
All States
BRANCH OFFICE CLAIMS HANDLING
File Organization
Information in any file shoifid allow bofii the person assigned to file handling and others to locate and use
important information. File organization should complement the decisions and enhance timely, accurate,
decisions.
New mail received is prepared and seamed into the ima^g system, hiimediately after mail is Scanned into
the systemsy it is indexed which is an electronic mail delivery system. The claim associate listed as the
owner on the file will tliein receive an electronic "task"advising,new mail has been received on the
file. Claim associates will revie^y the new mail,handle appropriately and move the mail to the correct
folderfor storage and reference, hriportant informatidn such as policy information and loss notice can be
flagged for easy retrieval.
in Guidewire GlaimCenter,the mail may be fh^her organized by its relationship to involved parties,
exposures arid other elements. Ifa note about the mail and.the. activity it yields is created, and the claim
associate related the documents tp the note,the abiHty to assemble topics thatinvolve multiple documents is
enhanced by the "notes""search"capabilities.
For example^ if a claim involves multiple Property Damage(FD)claimants and tlie documents for each
claimant are "related"to notes and exposures for each individual PD claiinant, a claim asspciate would
search the notes for the name ofone PD claimant. "Related" items would be organized in the notes section
when the claim,associate wants to see all the notes and dpcurnents in the history ofthat one person's claim.
CONFIDENTIAL
Ail States
Closing File Procedures
When a payment on a reserve is made which the claini as believes concludes handling, he/she should
request-that the coverage be closed. Ifit is the only or final reserve open on the file;, he/she should request
the fife:be closed, subrogation pj: salvage is still pending,an.indicator should.Be opened on the file, but
the reserveshould still be closed.
File closing procedures for Guidewire GlaimCenter claims are detailed in that system.
Closed imaged files renoam in the imaging system.
Closed paper files should be prepared for shipment and s^t via FedEx to Stored Records at the Crcyts Road
Facility. It is import^t that the,contents Ofeach file be festened to keep the material together. All reserves
should be closed befbre shipment.
DO NOT Destroy FILES

Files involving bodily injury to a minor,structured settlements or oilier reasons to extend the destruction
date ofthe file, should be considered by the claim associate. All ês are kept for several years,,but ifa
certain date is needed,the claim associate should calculate a destruction date which is well beyond the latest
time a claim could Be contested/pursued. Consider the presence ofiegal documents,Or claims that involve
minors when calculating destruction dates. For PIP,the likelihood that future treatment related(or claimed
to be related)is important.
Both Non-Imaged and Imaged files need to be considered for a Do Not Destroy.Date.
• Non-Lnaged files should have an orange sticker placed on the firont ofthe file indicating the year
the file can be-destroyecL
• Lnaged files should have a black file mark set on the file in ImageRight and the Do Not Destroy
indicator needs to be Setunder Option 10 in KCNG. For instmctions on how to set this indicator,
pleiaae see How to Set the Do Not Destrov Indicator.
Ifsubrogation or salvage h^dlmg is active, the indicator should be verified that it is present on the file. Ifa
supplementalpayment may be made for example on a collision reserve, the claim associate is able to pay it
on a closed reserve. However,ifit is determined there is a continuing exposure, a reserve should be
reopened- A reopened reserve should be sufficient to cover the total ofall previous payments plus aR
anticipatedpayments.
CONFIDENTIAL
AU States
Folicv Docamentatioii
Nearly all current policy declaration information is available throu^ various systems. Samples of most
poifcy forms are available,ôijgb A: e^Libiary* KNOT,option 6^ Policy i)ec,Info provides some
preliminary policy informationrfor most policies.
Current policy information is available throu^ the USYS screen^ Searchesmay be conducted by policy
number or the^plicyholder's nanie. Policy declarations, and forms on the policy,can usually be found
using the Underwriting link on the intranet at www.aoins.com.
Iffurther,policy inquiry is neede4:the'branch underwritiug offices can provide assistance. Certain claims
may warrant,contact with an agency for coverage information.
Ifthe resources above are not Sufficient, an additional resource to Consider is Home Office Stored
Records; If older policy tenns are needed, this may be an ^propriate solution.
ifpolicyrecords are needed for evidence to be submitted to a court, or for other types ofpolicy requests,
CMtifled.cOpies ofpolicies naay be necessary. Assistant manager/manager approval of such requests is
required. When requesting a Certified Declarations the form must include the name and telephone
extension ofthe managementassociate who approved the request. FOr step by step instructions, claim
associates may Click on the fplipwing link, Certified Dec Instructions. For additional information regarding
certified Declaration Request,click on the following links. Claims FYI87: Declaration Copy Request
Claims FYI Issue 105: Declaration Requests - Procedures and Considerations
All policies obtained, wMch are to be provided to attorneys or insureds, should be reviewed by the claim
associate for completeness and accuracy. He/She should confirm that the policy information is accurate and
supports the coverage position on the claim.
Requests for older policy information on environmental claims may be done following consultation with
Home Office Claims per fiie Environmental Claims - Policy Search section ofthis Guide.
CONFIDENTIAL
All States
Notice of Claim
Auto-b\yners'goal in the Claims biyision is to achieve customer satisfection througji quality claim
service. An integral part ofproviding "service" depends on the quality ofcommunication with their,
customers.
Auto-Owners'independent agents contiiine to bethe primafy avenue for their insureds to use when
reporting a claim. They are Auto-Owners^ first contact with an insured on their claim.
While it is preferable for clmms to be mpo^d ljirpugh the insurect's agent, tbere are times,;when an
associate in the Clairns.Division should take a clainii diieetly firom the biistomer, whether it is an insured, a
claimant or other Taking less notices at Auto-Owners is an important partofproviding quality claim
service. The followihg should be considered when taking a loss notice ffom a customer.
• Ifthe report ofloss is from the insured, aiid they have not reported itto their agent, consideration should
be given to referring them to their agent ffithey have been unsuccessful:in reporting the loss to their
agent, for whatever reason,the Auto-Owners associate should take the loss,notice and refer itto the
appropriate claims branch.
• Ifthe report ofloss is from someone other than the insured, and they have not reported it to the insured's
agoit, consideration should be given to refating them to the ihsured's agent Ifthey have been
unsuccessful in.reporting the loss to the ihsured's agent, for whatever reason, the AutoÔwners associate
should consider the.following:
o Ifthe claim appears to be straight forward,the associate sliould take the loss notice and forward
it to the appropriate claims bmhch for handling. The associate should indicate On the loss report
the name and interest ofthe reporting party,
o Ifthe claim is complex,in nature or needs indmediate attention, the associate should forward the
call to the appropriate claims branch for their assistance. The call should be announced to avoid
any delay in moving the claim forward,
o Because the loss was not reported by the insured, tbe claim,associate should inake every effort to
confimrloss details with the insured and others before reaching decisions on coverage, liability,
or damages. Other contract elements may Come into play and should be managed based upon Ae
situation.
• Afler the loss is set up, the agent will receive the claims acknowledgement providing them the claim
number..
Auto-Owners' goal is to provide quality claims service wlien taking calls from their customers wanting to
report a claiin
When a claim is being reported to Auto-Owners or their agencies, obtaining a.thorough and complete loss
notice reportis an advantage. Ifthe claim will be handled throu^the reporting branch,the claim associate
should provide the necessary information to the customer. If the claim will be handled by a different claim
branch,the claim associate should fOrw^d the report to that brrnich and advise the customer ofthe
process. A customer reporting a claim to Auto-Owners should have a "No Problem" experience.
A notice ofloss may be received fi:om agencies through the FfrstNotice of Loss(KNTC). The loss notice
will appear on KNTC immediately. Claim numbers are pre-assigned when reported through KNTC.
CONFIDENTIAL
WHen notice ofloss is received, it is iinpertant to p set up the claim enter it onto the
system. Accord loss notices should be complete to allow accurate data to be stored on the system. Training
ofagencieis to communicate Auto-Owners' needs mgardipg loss notices should be addressed.
Complete policy information, date Ofloss, number Ofthe scheduled automobile, property
location/description, loss payables, mortgagees^ complete loss descriptions and endorsements should be
provided- How to contact the insured and claimants,telephone numbers^ etc. should be provided. The
driver's name tor the insured's vehicle should be provided Claimants'names, contact intbrmation and
addresses are important If an agency presents a loss notice without a date.ofloss Of a loss description
which says "unknown," the branch should complete this data prior to set-up. Auto-Owners is dependent on
the quality and accuracy ofall data entered on the system.
When Auto-Owners offices are closed and a customer is ti^g tO report a claim,there;is a backup process
in place through which the customer can obtain basic information. When that occurs,the claim branch
should receive notice through that system and handle the claim appropriately.
Ifa loss notice is vague or inaccurate, especially if it occurs regularly from a specific agaicy, efforts to
discuss expectations are important to improve both service and mutual understanding.
In some states, agents who are not Auto-G wners licensed agents are able to place insurance with Auto-
OwnCTS in an assigned risk plan. They may not be obligated to take and submit loss notices in which case a
claim associate should take the information and begin the claim handliug process as needed.
CONFIDENTIAL
AJl States
BR^CH OFFICE CLMMS HANDLING
Loss Coverage Coding
Claim cocUng allows statistics tp be kept on the fiequency and seventy ofeac ofclaim for which
AutoGwners wishes to gather data. The accuracy ofthis data is essentiaL
A section ofcoverage codes are available for each broad area ofpolicies. Each code has an alpha and a
numeric designatipn. Auto-Owners uses:these alpha codes on all claiim^les:
The codes are provided on the Coding Sheet,form 18667. Claims codirig help is available on the BCHLP
screen.
When setting up a new claim or during the process pfhandling a claun, it is important to have the correct
coverage codes open on each file. In the course ofhandling a claim,^ts or circumstances may come to the
claim associate's attention that requires the claim coding to be changed. When claims epding questions
cannot be answered within the branch, branch;associates should consult with a Home Office Claims
EKaimner. Ifchanges need to be made, please contact Home Office GMms Branch Support.
As Guidewire GlaimGenter start$, the process for coverage and other coding changes. SpecifiO instruCtipns
exist in that system.
CONFIDENTIAL
All States
Claims Outside of the Branch Territory
Some 0laims niay reqtiire. handiiiig ffOtn oiitside ofthe branch's teiritoty. TOen this occurs,it is important
to consider the type of activity required. Manytimes^ the claim should still be handled from the origmating
branch, Epr example, a simple automobile appraisal in anolfrer state, or assigning a subrogatipn attpmey
can all be handled within the originating branch.
Due to differentlaws,,claims outside ofthe originating state involving liability issues^ such as Medpay
Coverage or PIP for exampiej may require the partial assistance ofthe branch in the state where the accident
qccuired. Sometimes it is.beneficial to have the assisttng hrandi handle the entire chjm. For example,Ifan
insured from the originating temtoiy is on vaeationibr aConsiderabie aniourit oftime in another state and
has had an accident which requiresaliability investigation the branch responsible for die territory where
the insured is staying Should handle the entire file.
The branch assistantmanager/mariaget should be Consulted ifrConSideration should be made;for a Claim to

be handled by another branch.: It is helpful ifthe branch assistantnmager/manager from the originating
branch would contact the respective branch assistant manager/manager to advise ofthe claim. A claim
should only be:sent to another branch for assistance when approved.by the branch assistant
manner/manager^ if available.
Guidewire ClaimCenter processes to move claim handling to another branch are further outlined In
that system.
The.branch which can provide the best service,possible shouldhandle the loss. Providing super outstanding
service should be the ciaim associate-s piiinary concern. The physical address ofthe insured, claimant or
agent is only as relevant as the facts ofthe loss. Good judgment should be used when deternriniiig ifaloss
should be transferred.
Below are some things to consider when asking another branch for assistance.
Partial Assistance
• Origmating branch should 5et up the file,
• Originating branch should provide the assisting branch with recommendations for assistance,
• Information may require cohimunication and coordination between branches.
• Assisting branch should acknowledge the receipt,ofthe file documentation.
• Assi$ting branch should upda.te the branch hanging code and claim aSspciate.number for the applicable
coverage in the KIPOL screen.
• Assisting branch should periodically update the originating branch on the status ofthe claim.
• Assisting branch is required to monitor the reserves aiid handle any Home Office repoiting which may
be necessary.
• When the assisting branch completes their portion oftlie claim,they should forward their file
documentation to the originating branch with a closing report. They also need to notifi^ Home Office
Claims Branch Support to remove their manager's markover.
• Origmating branch cannotclose their file until they receive the closing report from the assisting branch.
Full Assistance
CONFIDENTIAL
• Oii'âting br^ch should promptly refer the;loss td the;apprdpiiate brahdh.

• Assisting branch should acknowlMge receipt ofthe loss and handle as a noimal branch file.
Florida Liability Glaims

It is notuncommon for insureds, who are not Florida policyholders,to have an accident while traveling in
Flori(k. m additibn^ other ihslireds may have activities that yield claims in Florida.due tojunsdiction.
Florida's unique,exposures benefit from associates accustomed to dealing with FloridaLissues taking the lead
m handling claims where the bodily injury(BI)claimant or property damage(PD)owner;is in Florida.
Upon receipt ofa claini where the BI claimant or property damage owner is in Florida,the branch
• Identificatibn ofthe Florida branch handling that locale can be accomplished through A-0 e-Library,
Claims Branch Mans, where it breaks territories by county.
• Review pending claims in ±e branch with each claim associate. Identify any claim with Florida
claimants.
• If any pending BI or PI)claims are identified where Florida jurisdiction is mvolved, unless that claim is
settled and would experience delay because offile transfer,that claim should be summarized and
for\varded to the Florida brmch handling that locale. Ifretained, such clahn should be resolved without
delay, with the manager's markover to assure delay is avoided.
• Any file trmisferred should be handled with sufficient priority that there is no delay in the contact or
follow up with the parties involved. Each manager is asked to confirm that the transfer process is
proceeding on atimeiy basis for files m their branch.
• involved.parties should be advised in an appropriate way(telephone, letter, botli?)that fiieir claim is
being handled by the destination branch to maximize service. Ifa positive relationship exists, special
handling to introduce the successbf claim associate may be advisable.
• Ifthe file has been reported to Home Office Legal, you should send a memo tp Home Office Legal
advising them ofthe transfer, and the destination branch, to allow smooth transition in reporting to that
new branch's supervising attorney,
Florida Branches handling such refefred files should;

• Acknowledge receipt ofthe refefmd portion ofthe file.
• Beport to their own supemsing attorney to allow jurisdictional references to be incorporated most
easily.
fÔMFinPMTIAI
^WINr IL-*I_.I^ I lini- CawthomAO-CHG00013
V. Auto Owners
AJl States
GAPTIONED REPORTS
Liability
These rejiort:headings are not all inoiusiye. The investigation may develop or reveal other:topics or issues
that will need to bo addressed. The documents referenced in the captioned report should be included with
the report to Home Office Claims or Home Office Legal.
Descjrlption of Loss
• Discuss the statement offacts.
• Describe the cause ofthe incident
• Give a briefdiscussion ofstatements jfrom the insured and claimant.
• Describe scene ofincident.
Coverage
Describe the policy kinds involved, who is insured and how parties involved relate to the
named insurecL
• Identify all parties involved in the loss, directly or indirectly and how.
• Give policy numbers,date Ofloss, effective policy terms.
• Give scheduled vehicle, a scheduled or a permissive driver and their address,
• Identify any ajppliCable limits ofliability,
• Describe which pohcy forms and endorsements present any coverage issues,
DisCuss the coverage position.
• Ifthere are coverage questions, discuss the investigated relevant areas and what documentation was
obtained for clarification.
• Is a reservation ofrights in order? Why? Has the reservation ofrights been sent already, or is a draft
for review included?
Property Damage
• Is the insured liable? Why? Please identify ifthe state recognizes levels ofcomparative fault and
diScuss to what;extent.
• Describe the property and damages in detail,
^ Identify the claimant^ age and address.
• Who has ownership interest? Was interest verified?
• Discuss the'claim reserving^
Bodily Iniurv
• Give names, addresses and ages. Itis important to identify ifthe person is aminor and,ifso, his/her
parents or legal representatiye/guardian.
• Describe the contact,the information fiom statements and any importantinfomiation firom the
investigation.
• Brieflydescribe and summarize the mecfical reports available.
• Give atotal ofknovm medical cost incurred to date. Also, ifthere is a component ofclaimed medical
expenses that is believed to be unrelated to the claim, please address and quantify such unrelated
expenses^
• Identify the name ofthe legal counsel that may have been retained by any party involved in the loss.
• Is the insured liable? Why? Please identify ifthe state recognizes levels Ofcomparative feult and to
what extent.
• Discuss reserving.
CONFIDENTIAL
Police. Fire Reports

• Who investigated? What are their luidihgs?
• Discuss the status ofany investigation.
• Is their case open or closed? Court hearings? Status oftickets, charges?
ISO ClainiSearch
• Identify whe:dier an ISO GlaimSearch Match Report was receiyed. If yes, enclose a copy and describe
the observations. If a claims inquiry was conducted, enclose the documentation and describe the resiults,
Photoâphs.Diagrams and Maps

• Describe each item ideritiWirig the name and address ofthe person who provided it
• Describe the iinportahce ofthe date taken, location involved and relevance ofeachi
Damage to Auto-Owners' Policvholder*s Automobile

• Describe the damage to the inSuted's autp.
• Describe the point ofimpact to the vehicle.
• Describe the collision settlement progress,
Subrogation and Salvage

• Indicate whether there is subrogation/indemnification potential;identify documentation as well as
activities and responses to date.
Contribution
• Identify oth^ parties whose action, inaction or involveitierit.may require their participation,
• Describe,steps to get them involved, and status ofsuch efforts.
Witnesses
• Identify each witness by providing each person's name,address and age. Use a separate paragraph for
each.
• identify ifeach person is an interested or disinterested witiiess.
• Briefly diScuss the witnesses' statement,including its relevance/consequences.
• Provide any other prejudices the witneSs may have to any ofthe parties.
• Describe enough ofhis/her history to provide an idea oftheir oodibility as a witness. Remember that
ambulance,EMT and wrecker Operators are potential witnesses,
Medical Payments Coverage
^ Describe the injuries to whom this coyeê may apply. Ifit does not ^ply, why not?
Medicare Reporting
• Claimants name,address, date of birth and social security number,
• Ifthe claimant was 65 Or older on the date ofaccident, advise oit.the status ofreporting to Medicare,
• Ifthe claimant was receiving SSI or SSDI at the time ofthe accident, advise on the status ofreporting to
Medicare.
• If the claimant sustained a severe injury as a result ofthe accident(paraplegic, quadriplegic, severe head
injury, permanently and totally disabled as a result ofthis accident), advise on the status ofreporting to
Medicare.
• Ifthere is a probability that at the time ofsettlement the claimant may qualify for benefits under
Medicare due to age or physical condition(whether related to the accident or not), advise on the status
ofreporting to Medicare.
^ Evaluating whether the claimant will be entitled to Medicare benefits on the date ofsettlement is an
ongoing Obligation.
M CIDP MXIAI Cawthom v. Auto Owners

ILÎ_IN I l/-M_ AO-CHG00015
Siiminarv
• Provide a Summary ofthe claim associate's opiiiioh as to coverajge, liability and damages.
• Include recommendations while using discretion andjudgment
• Ifthe branch assistant mahager/manager is involved,jprovide their input.
Settlement
• Describe eflforts fpr structured settlement proposals.
• Describe the claina associate's Settlement evaluatioiis,negptiations and settlements for each Claimant
• Ifsettlement authprity is being specifically requested,include in tiiis section. Authority should be in
addition to the evaluation.
Fiirther Investigation
• Describe the plan for the further handling ofthe claim.
• Name of local counsel assigned to defend insured, if applicable and ifsuit has beeniiled.
Possible Enclosures
• Loss Notice
• Declarations Page
• Police, Fire Reports
• Photographs, diagrams, maps
• Aj^raisals, estimates ofdamage
• Expert reports
• Summons and Complaint, ifsuitexists

• Coverage Position Letters, Excess Letters
• Medical reports and relevant infornoation to support the claim associate's comments
• Representative correspondence
CONFIDENTIAL
^ All PIP States

GAPTIONIP KEPORTS
PIP
When a PIP jSIeis reported to HomeQfiice Legal orHomei Office:Claims, a Captioned Report shdiild be
completed by the claim associate; Once completed,the Captioned Report should be placed in the branch's^
imaged file. The claim associate should.notify either the attoniey in Home Qfifibe Legal or the pff Claini
Examiner that the report is available for viewing and identify where it is located iti the file.
The heading ofthe report should indicate the date the report was writtenj the name ofthe defense attorney to
whom the file is being sent(ifapplicable),the name ofthe branch and handling claim associate. It should
also identify the file numberi the insured,,the claimant,^d the date ofloss. The body ofthe report should
contain Several categories that butlme the relevant information mgarding the claim and,if applicable,the
issues in litigation.
insiired
Identify the namedinsured,the policy number and term, and the motor vehicle;involved in the accident,
including the VIN.. Also,identify'the date ofnotice ofthe claitn,; whether a police repoit was obtained,and
whether any deductible applies.
*For Michigan PIP only, indicate whether PIP coverage is Primary or Excess.
Date and Descrlbtioa of Accident

The date and location Ofthe accident should be provided along with a description ofthe pertirientfects and
an analysis ofany subrogation potential.
PEP Claimant
The haine, address and date of birth ofeach PIP claimant should be provided. State the injuries alleged as a
result ofihe motor vehiqle accident. Indicate the employment:status at the time oftlie accident,the name of
the employervjob description,and applicability of wage loss benefits. Ifthe claimant is deceased as a result
ofinjuries sustained in the accident, each dependent and their date of birth should be identified. Provide an,
explaiiation ofthe coverage and priority analysis for each claimant Include infOrmaiiott oh ahy health
insurance coverage ayailable.
*FOr Michigan PIP only,indicate whether the claim associate has requested the claimant apply for Social
Security Disability Insurance and advise ofthe current status ofthe request.
Medicare
indicate whether any claimant is Medicare eligible, whether the claim has been reported to Medicare, and
describe the extent ofMedicare involvement including,any lien that has been asserted.
Reserve
The current resefve and amount paid should be indicated. Any recommendations for future revisions,should
be outlined in the comments section ofthe Captioned Report.
Pialntiff Attorney (If applicable!

Provide the name ofthe attorney and the name and address ofthe firm. Include all known contact
information such as telephone number,fiicsimile number and e-mail address.
CONFIDENTIAL
All States
HOME OFFICE LEGAL
Introduction
It is importaiit to recbgpiize the criteria for deciding whether to refer a file to Home Office Claims or Home
Office Legal, The decision is often dependent on two criteria:
1. The amountofreserve and

2. The type ofloss & whether a lawsuit has been filed.
Auto-Owners seeks efficient coordination of verbal and written cominuhication betweeii the branch and
Home Office. A captipned report to Home Office is preferred at the tiine ofthe file referral.
Honie Oftice Legal is ayâble for advice and counsel on coverage or other legal questions whether or not
the questions pertain to a file formally reported to Home Office Legal.
CONFIDENTIAL
AJl States
HOME OFFICE LEGAL
File Handling
Home oMce Legal reqixesfe that no attachments Or documents be sent to Home Office Legal when these
materials reside in Imageffight-, Glahn asspciates should provide a summary ofthe materials and mark
relevant material by placing: a page mark on the ffist page of a.document and,updating the document title;
They should categorize and totd the medical billsrepeiyed. Ifa differpiit Home Office Legal attorney
responded to a reports, the claim associate should cohtliiue to respond to the liormal attorney unless
specifically directed.
Home Office should be advised ofciurerit reserves oii files and of all changes. They should also be notified
if a reserve has changed which now changes,the file's status to being over branch settlement authori^-
Reqûests for settlement authority fiom Home Office should include the branch's analysis of coverage,
liability and daihages. eValuatiPn should be provided ofeach as well as recommendations along with
direction to tlie supporting documentation within the file. Requests should be presented well in advance of
mediation, settlement conferences Pr trial.
GOmmunication or cerrespondence fiom Hpme Office should not be passed to third parties including
defense counsel. If an exception is needed, consult with Home Office Legal. When branch associates are
dealing with third parties, associates should take fiill responsibility for the handling oftheir file and not
advise of Home Office involvement.
In prepmiiig materials to share with Home Office Legal,the Glaim Associate should:
.1. Review documents and identify those with specific information that adds value tp understanding
the case. A page mark should be appli^ to the first page ofa documentfor ease oflocation, and
the document titleamended to reflect the nature ofthe document
2. Summarize the documents and their relevance to the claim including any reconnnendations for
further handling or additional documentation which may be needed.
3. Medical records,should bereviewed and reduced to the most respective and meaningful
information. Page mark-those records which provide key information on the claimed injuries,
like diagnostic studies, operative repPrts, and discharge summaries.
Initial nPtice Pfa claim repprted to Hoine Office Legal shPuld.be sent to
Legal.lma4zeRitzht.Files@aoins.com or Legal.hiiageRrght3.5.Files@aoms.com depending on the version of
hnageRight the branch is using;
CONFIDENTIAL
All States
HOME OFFICE LEGAL
Branch Settlement Authority Files
When a file isap>propriately reseiyed^ w branch settlêntauthority,no further report tO Honae Office is
needed after your initial captioned report in some cases. Boine OfSce Legal niay require a report in any of
these ihstanOesr
1. The claim is settled;

% New facts havenome to fi^trequiring raising the reserye tq legal reporiihg levels; pr
3. Trial is scheduled to start within 2 weeks. Atthat time;, a pre4fial reportfirom the defense attorney
should be subniitted to Home OfiSce Legal. This report should detail the issues to be tried and
include an estimatedjury verdict
Ifcoverage or legal issues exist. Home Office will need continued involvement When coverage issues
exist, there is no branch authority, Any attempts to settle files with coverage issues need,approval from
Home Office. This is true for claims ofpersonal injury and advertising injury as well. Ifthe claim
associate's evaluaiion and request for settlement authority is within branch authority, a report should bo
directed to the branch manager When a branch authority file is settled. Home Office Legal still requests
drat diey receive clOsmg documents about 14 days before die branch file is closed.
CONFIDENTIAL
AJl States
HOME OFFICE LEOAL
Umbrella Policy- Claims
All claims msing out ofan ihsuieci's umbrella poUcy shall be referred to Home Office Legal, The brahch
shpnldnot refer the defense ofa claim or lawsuifunder an umbrella policy to an attorney withoufdrscussm^
with Home Office Legal, Defehse coverage under an underlying liabiiity policy wbiild nonhally be
primary.
Claim associates should consii^r whether an msured has'an umbrella poUcy. This iirformation should be:
provided to Home Office Legal and generally a file should be set up.
For more information, please see File Reporting Thresholds.
/^C\MP|r)FM"r| A|
IL^L_IN I ir^L- CawthomAO-CHG00021
V. Auto Owners
AJl States
RESERVES/FILE REPORTING THRESHOLDS
Introduction
Each claims associatecis respoi^sible for the properreserving ofciaun £Qes.
A claim reserve is an estimate ofthe;total cost Autp-OAraers ihight pay outon a claim. The prpcess:begins
with^ the notice ofloss and the facts surrounding that claim. The Jhcts should be examined and related to the
extentofpolicy coverages and Ihe amount ofdamages which maybe covered. When the;claim is set-up/the:
evaluation ofwhich coverages may apply to the claim and the amount ofpotential payments to be made
should be identifiisd Claim associates need to.develop a mental picture ofeach case and use his/her
judgment;in the first;step ofanalysis.
Ifa new property claim is receiyed,the loss report may say hail damaged a home on a hpn^sowner^s policy
insured for $80j000. Based on prior experiencej the claim associate knows hail is a covered cause ofloss,
and a roofis covered property. The claim associate has a pretty good idea ofwhat the rOpfreplacement
wOuld costi thus is pretty comfortable establishing thereserve atthe:estimated replaceniient cost ofthe foOf
ifthat is the extent ofdamage, Ifin the course ofthe claimi Ihe insured elects not to replace the roofand.
claims only the-ACV settlement,the originaLreserve is still appropriate.
A liability claim presents some additional issues. Coverage, liability and damages are to be considered.
Examples may include a faulty work exclusion which may preventpayment for a part ofthe damage. The
extentto which the insured might be found liable must be factored into die evaluation. If comparative
negligence is appiicable, it may ledace the possible aitiOunt of.damages owed. The duration and severity of
injury would induence the valueand payment ofdamages. For reserve purposes,the financial exposure to
Auto-OWners must be evaluated.excludmg LAE considerations.
A workers compensation claim requires a differentthought process. The file,should be reserved based on
what is known and reasonably expected for the circumstances ofthe claim. Aftimos, consideration for
lifetime benefits inay be necessary. Ifthe claim exposure indicates lifetime,benefits,then the file should be
reserved accordingly, Particular attention should be paid to those.files Which haye been open for an
extended period oftime. These files could be the ohes;most likely to show continual step reserving aiid
could be under reserved. There are tim.es when circumstances completely change On a fUe andthe reserve
needs to.be reviewed..
A workers compensation claim reserve should be evaluated and set on a file within 30 days ofreceipt ofthe
loss taking c^ to raise the reserve within the year the claim was reported. It should also be.evaluated each
time a medical or wage loss payment is issued and/or the facts or circumstances ofthe loss change. Some
common iriggers that,may affect the reserve Could be approval ofa surgery or receipt ofa demand letter.
Reserve changes should be documented in KNOT and should outline the factors considered by the claim
associate when establishing the reserve.
A Personal Injury PfOteclion(PIP)claim has the potential exposure for lifetime benefits The reserve
should take into account the extent ofhijuiy, resisting disability, and related medieal treatment Files which
remain Open should be regularly evaluated to ensure the reserve is^propriate. The claim representative
should be mindfiil Ofthe reserve when issuing a payment. A PEP reserve should ideally be evaluated and set
on a file within 30 days ofreceipt ofthe loss and within the calendar year the claim whs opened. The claim
representative should documentall reserve changes in the file and oufiine the elements considered when
establishing the reserve!
CONFIDENTIAL
Each time a file is handled^ consideration should be made whether the proper coverages have been
a;ddressed ^d ifthe reserve is appropriate. A reserve change may be needed; however,fiequehtreserve
changes should be avoided. Investigation and obtaining sufficient information allows the claim associate to
estimate AutoÔ\vners' total exposure proihptly. Whenever a file is viewed on di^,the reserve should he
reviewed. Are they properly open or inadvertently closed, are they adequate,etc?
Ifthe claiin associate believes a payment is liJcely tb be a fin^ payment on a mserve, he/she shpuld close tlie
reserve wh& making the payment. Ifa supplemental payment is needed,a paymentbn a closed reserve is
possible. A reserve should not be left open w^ting for a loss adjustment expense(LAE)payment, a release
or salvage recovery. The file is properly closed with a payment ifthe involved reserve is the only remaining
active reserve on the file. All personal lines reserves(except auto BI & Î)may be closed at anytime it
has been determined no further exposure exist. Auto BI and RBI should remain open for twelve months
from the date the reserve was originally established. At that time,the reserve may be closed without fiirther
payment- The reserve may be closed if another payment is made during the twelve month period. The file
circumstances naight support keeping a file open longer.
Ifa claim reserve is established but no paymeritS are made,these files can be closed. This should be done
when it has been determined no exposure exists: All automobile BI and RBI reserves that are not closed
with a payment me.expected to remain open for twelve months before they are closed.
Sometimes a file will have two reserves Open and the claim associate is ready to pay and close one ofthe
reserves; Ifit has been confirmed the second reserve will not be actively neêdj the entire file can close at
the tiine ofparent. For example, a collision and Car rental reserve may be Open, Ifthe claim associate has
spoken to theinsured and is confident there will not be a car rental loss incurred, the aitire file can be closed
at the time ofthe collision payment Ifthe claim has a BI or RBI open reserve, mese coverages would need
to remain,open for twelve months^
Auto-Owhers uses factor reserves on many oftheir claims. A factorreserve is generally hftended to
represent a minimal exposure on a coverage. Use ofa factor reserve when a case reserve is more
appropriate can compromise Auto-Owners' expectatibn that their reserves are adequate. The actual dollar
amount ofa fector varies by coverage md may be considered an average ofroutine claims; They are easy to
use when setting up a claim. Ifthe claim associate recognizes the exposure On a clmm will likely be above a
fector,h^she must establish a case-specific reserve. The case reserve should represent the total exposure on
each coverage applicable to a claim. The case reserve may be established when the clahn is set up or later.
A reserve may be opened using a &ctpr; however,the reserving evaluation must be an ongoing process.
The reserve should be re-evaluated every 30 days on Open files.
Attention to detail on reserving affects the financial stability of Auto-Owners.
CONFIDENTIAL
All States
RESERVES/FILE REPORTING THRESHOLDS
File Reporting Thresholds
Accidental Dcatli
Advertising Injury
Bodily Iniiu'v
Bonds
Construction Defects
Directors & Officers
EIFS Claims
Environmental
EPLI
First Paitv - Propeilv
Fmud/Arson
Lead. Asbestos
Personal Eiiui'v
PIP
Professional Liability
Property Damage Liabilit^
Suit Anainst Company
Umbrella Liability
Workers Compensation
*FRAUD/SUSPICIOUS CLAIMS
Department for Report and
lype of Claim Threshold/Reserve Activity
Supenlsion
Fraud/Suspicious Claims All claims Special Investigation Unit
*ARSON
Type of Claim Threshold/Reserve Activity
Supervision
Arson All claims Special Investigation Unit
*Fraud/Arson Oaims - Claims inyolying potential fraud and/or arson are required to be reported to the
SIU tlirough the referral system. No captioned report is necessary for submitting a referral to SIU. Ifthe
claim also meets reporting requirements due to the size oftlie reserve(s), it should be reported to Home
Office Claims in addition to a referral to SIU. The claim associate may review the section in tlie Claims
Handling Guide; First Party Property Claims, Suspicious Losses - investigation.
BODILY INJURY - AUTO
Threshold/Reserve
Threshold/Reserve
Activity Department for Report
Type of Claim Activity
Commercial Auto and Supervision
Personal Auto Kinds
Kinds
Kinds-01,05,06,10, Kinds-02,03,04,08,
Auto
11,16 46
BI, RBI, UM,RUM, Under 40,000/suit Under 30,000/suit *Branch Authorit

Initial Report: Home

Office Legal
BI, RBI,UM,RUM, 40,000 & greater or 30,000 & greater of
Home Oflice Legal
UIM coverage question coverage question
BI,RBI,UM,RUM,
40,000 & greater/suit 30,000:& greater/suit Home Office Legal
UIM
BODILY INJURY-!DTHER THAN AUTO

TIiresliold/Reserve
Activity Threshold/Reserve
Department for Report
Type of Claim Homeovvners, Dwelling ; Activity
and Super>ision
Fire, Mobile CommercialPolicies
Homeowners & Farm
*Branch Authority
BI. Under 40,000/suit Under 30,000/suit Initial Report: Home
Office Legal
40,000 & greater or 30,000 & greater or
BI Home Oflice Legal
coverage question coverage question
Bi: ' 40,000 & greater/suit 30,000 & greater/suit Home Oflice Legal
*Brianch Authority Initial Report: Home Office Legal - Refers to those claims that require an initial
preliminary report to Home Office Legal with the appropriate file documentation. After initially reporting
the claim to Home Office Legal it may be settled within Branch Authority as long as the file reserve remains
within Branch Authority. No further correspondence may be required between Home Office Legal and the
Branch until the claim is settled. However,ifissues regarding coverage, liability or damages still exist,
further reporting to Home Office Legal may be required at their discretion. Prior to closing the file, closing
documents should be sent to Home Office Legal.
If^ during the course of handling the file, the reserve is raised above Branch Autliority the claim associate
should provide Home Office Legal witla a report summarizing the activity that has transpired since the initial
report and continue to correspond with Home Office Legal through tiie conclusion ofthe file. This file will
no longer be a Branch Authority file.
FIRST PARTY PROPERTY
Type ofClaim Threshold/Reserve Activity Department for Report and

Supervision
Combined reserves 125,000 and
Personal Lines Home Oflice Claims
greater
es 50,
Commercial Lines Home Office Claims
All claims involving sinklioles, mine subsidence, biohazard, occupancy

Home Office Claims
issues or placed in appraisal
Combined reserves 50,000 or
Equipment Breakdown Home Oflice Claims
greater
Note; Due to the split reserves on losses, reporting thresholds now represent the sum of all file reserves.
FIRST PARTY AUTO

Type of Claim Threshold/Reserve Activity
Supervision
Comp; Collision Over 100,000 Home Oflice Claims

All States
TfflRD PARTY LIABILITY
FilesReferred to Home Office
Glaiin files ijivplving reserves of criteria which require the need for referral to Hcjne Office, Claims pr
Legal,require the claim associate's prompt referral and completion ofa Liability Captioned Report It
should present the facts ^thered through the investi^tion, questiPns which stiU need to be answered,and
the claim associate's plan for fiuther handling ofthe claim. Judgment should be exercised in deciding the
format and the content presented.
Claim handimg is a process and the claim associate should rôft the ongoing process as a part ofthe
evaluation. Continued reports to Home Office should be made as significant information is received. The
claim associate should provide their comments to Home Office ph material which is being pfovided to
Home Office. A sample captioned outline for initial reports to Home Office for various claims is prpyided;
Reporting Instructions to Home Office Claims:on ImageRisht Files
When initially reporting a file to Home Office Claims, it is necessary for the claim associate to fax,email,
Or mail only fiieir Liability Captioned Reportto Home Office Claims. The preferred method is email. The
email address is HomeOffice.Claims.Corr@aoins.com. Home Office Claims can then relate the branch
file in ImageRight to the Home Office Claims'file and review all the documents. It is not necessary to send
any other documents that are contained in the branch file as Home Office Claims has read-only access to
that file materiah
Captipned reports outlining the claim associate's thoughts, opinions and recommendations are still part of
the reporting expectations. In addition, because the file is imaged,the claim associate will need to
specifically reference which documents they are relying on and wheare they are located within the
ImageRight file(i.e.: page # aud folder name).
*This pertains to reporting to Home Office Claims on ImageRightfiles only. Please refer tp the Home
Office Legal-File Handimg section ofthe guide for details regarding reports to H6me Office Legal. Initial
notice ofa claim reported to Home Office Legal should be sent to Lepal.TmageRightFilesâoins.com pr
Legal.ImageRight3.5.Files@aoins.cPm depending on the version ofImageRight the branch is using.
CONFIDENTIAL
All States
TfflRB PARTY LIABILITY
Liability Investigation and Docmnentation
Documenting and preserving the fects and evidence in a liability investigation are important. Many tools
are available to accpmplish.ibiis documentation. Telephone contacts,recorded/written interviews,ISO
ClaimSearch,letters, sCehe inspections, photographs, measurements and diajgrams are a few.
Through the documentation ofthe facts,,the claim associate is able to better determine whether the insured
is legally lia^blei A person's duty ofcare towards others is often deternuned by applying a "reasonable
person" test. How would a reasonable person act when presented by the same or similar set of
circumstances? Ifa peison did not act in a similar way in a claim^ have thcyfailed to exercise reasonable
care? Ifthey did not act reasonably,they may have sOme liability of responsibility for ahy damages which
result
Any claim which may involve possible firaiid should be reported to Home Office Claims. The red flags of
suspicious claim indicators should be identified and investigated. Prompt reporting ofthe claim to HOme
Office Claims is important as it enables the bfanch and HOme Office Claims to work together during
investigation. The Special Investigation Unit(SID)in Home QfiSce Claims is available to discuss and assist
with these claims.
The Claim associate should Consider defenses offeasOhs why the insured may nOt be legally liable. A good
example is to consider whether the applicable state has a comparatiye negligence laW' There are many
facets to exanoining liability^ and they do vary by state. Determining the comparative fault ofthe parties is
dependent on thefacts disclosed thfou^ investigation. The relafive negligence ofthe parties may influence
the possible recovery, or even prohibit recovery.
Areas to consider when determining liability are"what is the duty Owed?" and "what is the duty breached?"
When someone is injured on mi insured^ property, it is necessary to determine ifthey are an invitee, a
permittee or a licensee. An invitee is someone who enters a place of business. They are invited on to the
premiSes.^ A perniittee is someone allowed On the premises stich as sOmeOne walidng across an open field
and the property owner does not mind or care. A licensee is someone expected to be on the properly such as
someone providing lawn nmiiitenanCe. The duty Owed to an invitee may be much greater than a permittee.
The investigation into the facts ofa loss will help determine ifthe insured has any liability or has breached a
duty.
Investigation and documentation ofthe damages sustained is necessary. Property damage may require
inspection,itemization, photographs, written estimates,ete. Bodily injury claims require consideration of
damages including medical bills, wage l0s$ mid other out Of pocket expenses. Correlation between the
current injury and the accident should be verified investigation and communication with clahnants are
important in working toward a prompt resolution.
The Claim file reserving should provide an evaluation based on the overall potential value ofa Claim. It is
important to consider coverage, liabiHty, damages and the investigation ofthe claim.
A release should be obtained when settling a liability claini. Expectations for obtaining a release should be
discussed early on with the claimant. Payment without a release may not terminate the claim^ Payment to a
claimant without a release is realistic only when damages are clearly defined, asis liability and nO chance of
CONFIDENTIAL
continuing controversy. Additional^delineS can be found under Third f'artv Liabilitv Releases and Tvpes
of Releases;
Advance payments on liability claims are not recommended; Prior to making an advance payment on a
liability cldm,thefile should be reported to Home Office GlaihQS and approvaii should be obtained.
Property damage and bodily injury claimants often expect to be paid as the expenses related to their claims
start to add up. Ifitis possible to assemble and calculate a value oftheir claim, repairs or treatment do not
have to be(^mpleted to conclude a claiin. A claimant's reluctance to settle may preventthem fipm actually
settling. However, offering to consider settlênt atim earlier time is an alternative to requests for an
advance. In such situations, a release should be considered to effectively resolve the liability although that
is often the stumbling block for the claimant.
ISO GlainiSearch
The claim associate should identify whether an ISO Match Report was received on the claim. If yeSj the
claim associate should describe whether or not the matches are relevant to the claim and the reasons why.
For example,if there is a relevant match, did the claim associate consider contacting the adjuster for the
insurer on the matched claim to learn more? It is recommended that observations are documented.
Ifan ISO. Claims Inquiry is conducte4 the results and what is found should be documented m the file. Ifthe
matches were relevant to the claimant's injury or property damage for the:claim being handling,the claim
associate should explain and print the relevantmatches for the file. Ifadditional investigation iSneeded,the
file should reflect what was done and the results, ISO searches or ISO Match Reports were reviewed and
discarded,the claim file should document.thiS; The decision to discard ISO fôrts should involve
Consideration ofthe available information and whether it naight be usefiil in future related Or unrelated
claims.
CONFIDENTIAL
All States
THIRI)PARTY LIABILITY
Releases
Haying eiaimant(s) sign a releasie when a liability eMna is settled provides many benefits. It is.evidente ofa
contraet demonstrating agreement on tlie deseribed teims. It demonstrates finality between the parties. It is
It is essential to have the proper parties sign the release. Ifproperty belonging to a coiporatibn is damaged,
the claim associate needs to identify die proper corporate officer to sign a rolease. Ifa settlement is £qr a
minor,a deceased person, or someone not legally capable ofsijghing a release, the claim associate should
document who is authorized to sign the release. This may feciuiie Probate Court approval, Aperson with
legal authority must sign a release to have a binding agreement
Outside attorneys should be furnished with Auto-Owners* release forms,so that it is not necessary for them
to prepare mostreieases-
Where a driver ofthe insured's vehicle was someone other than the named insured, both the driver and
named insured should be inserted into the release so tliey are all being released.
Auto Property Damage
Ifthe investigation is the basis for paying 100% ofthe damages considered legitimately claimed and there is
no continuing controversy,a release is the claim associate's option. It may be a full release or a release for
only the Property Damage. Anv claim where less than 100% ofthe damages are paid should be concluded
With a release.
Other Property Damage
Ifthe investigation is the basis for paying all ofthe damages considered legitimately claimed, a release
should be:
a) considered for claims in excess of$UOOO
b) obtained in exchange for paymentifthe claim is > $2,500.
Any claim Where less than 100%,ofthe damages are paid should be concluded with a release.
Bodily Injury or Other Kinds of Claims
An appropriate release should be obtained for any settlement,
Ifa claimant cannot sign his/her name^ a disinterested witness Should be obtained to read the entire release
to the claimant. After reading the release, have the claimant make his/her(X). The witness should then
write on the release,"I have read aloud the entire contents ofthis release to 'claimant's name', and I know
the person making this mark to be the person identified on the release,they acknowledge to me that they
understandthe release and I have witnessed the making oftheir X". The witness should then sign and date
the form.
OONPIDFMXIAI
VdfV'iNi 1L/L.IN I lOL- CawthomAO-CHG00029
V. Auto Owners
All States
TfflRDPAKTY LIABILITY
Comparative Fault
Nearly every state has provisions to alloGate &iilt ariiong parties in an aceijdent, Glaini,associates should be
aware ofthe provisions pfflie law in their state; and,in the accident state ifodier than their branch location.
To varying degrees, the aniount a person is able fo recover for a liability claim is reduced by the proportion
oftheir &ult In some states any negligence can completely bar their recovery. Claim associates should
know the law appUcable and^piy the &cts developed in their investigation to reduce payments for liability
based upon comparative fault.
Ifa Claiin associate concludes the insured is 100% responsible,the file doCmnentation Should clearly
support that conclusion.
OCiMpiriFNXI Al
v-fV/iNi iLyi-i\ I I^L. CawthomAO-CHG
V. Auto Owners
00030

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Case 6:16-cv-02240-JA-GJK Document 56-2 Filed 11/09/17 Page 1 of 178 PageID 1679

Prayers for Madison 2014

They going to do a cat scan on Madison's abdomen to

If you want to send mail to Madison they changed his

I still wake up thinking and praying for

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•••oo Verizon 3:27 PM -f 24%niD'^

1 meant to post this last night but it 1 posted it in the

Madison's hemoglobin numbers were down today so

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Diana Scott Reimink

Lifting Maddison and you all up in prayer.

April 23, 2014 ■ Like • Reply • O 2

•••oo Verizon 3:27 PM -f 23% DID'^

Iffl Prayers for Madison 2014

Madison had a restful night last night. His numbers

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Crossing our fingers, saying prayers, and

April 23, 2014 • Like • Reply •Q2

May God's healing hand be on Madison

April 23, 2014 • Like • Reply

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•••oo Verizon^ 3:28 PM -f 24%aiD'>

Great day so far! Madison is awake and smiling, he is

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Judy Wall Eiiiot

Dear Madison and Brad, God has

•••oo Verizon "9" 3:29 PM -f 24%QID'

^ Prayers for Madison 2014

Madison's fever is still high today and his white blood

lil Like Comment Share

Praying that his fever breaks soon. Glad

April 25, 2014 • Like • Reply

Praying Madison..hang in there buddy

April 25, 2014 • Like • Reply

Jill Marie Bodenheimer

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•••oo Verizon 3:29 PM 24%013f

Prayers for Madison 2014

Madison had a long day with dialysis, sitting up for

We would also like have a prayer tomorrow night and

Dear Lord please give Madison strength

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oo Verizon ^ 3:30 PM -f 25%[a'>

Prayers for Madison 2014

Madison just had his first taste of food in 24 days! He

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Yahoo! Go Team Madison! ....wonderful

CCT? we will continue to lift you up in

fo'] Write a comment..

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oo Verizon 3:40 PM ^ 30%kiZ>i

They reduced the size of his tracheostomy tube and

Today requests are for his kidney, spine, breathing,

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Rosemary Cawthorn Strickland

Healing day by day, step by step. Prayer

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