Bobby N. Harmon, CPCU, ARM
December 4, 2003
VIA fax only @ (559) 490-1919
Ms. Judith Neustadter
c/o Mr. Justin W. Schuck, Case Manager
American Arbitration Association
6795 North Palm Avenue, 2nd Flr.
Fresno, California 93704
RE: Updated Arbitration Disclosure Statement
Mary Lou Woo, Trustee v. Bobby N. Harmon - Case No. 74 166 00491 03 JUSC
Dear Ms. Neustadter:
This is in response to your letter of October 19, 2003, regarding your Disclosure Statement for the referenced case.
In your letter, you state that you have had “limited contact” with a number of entities listed in my letter of October 17, 2003; however you do not disclose the specific parties with whom you have had this “limited contact”. Would you please disclose the names of all such parties, and further describe, in sufficient detail, your past or present relationships with these parties or their counsel, direct or indirect, whether financial, professional, social or of any other kind.
Due to their relevance in this matter, I would ask that you please describe any relationships you may have with the following entities, whether limited or otherwise, who were included in my list. If you have had no relationships with these parties, would you please so state in your response:
James “Kimo” Apana (former Maui mayor); Jon Min; Elmer Cravelho; Sanford Murata; Kamehameha Schools; Estate of Bernice Pauahi Bishop; Nathan Aipa; Colleen Wong; Louanne Kam; Lyn Anzai; Gil Tam; Colbert Matsumoto; Sumitomo Bank; Jon Miho; Benjamin Cayetano; John Waihee; John Mullen & Company; Torkildson Katz Fonseca Moore & Hetherington; J.P. Schmidt (former Risk Management consultant for County of Maui, and current Hawaii Insurance Commissioner); Sandwich Isles Communications; Susan Tius; Sterling & Tucker; Steven Guttman, Esq., Kessner, Duca, Umebayashi, Bain & Matsunaga; Mary Lou Woo; Marr Hipp Jones & Pepper; Stanford Manuia; Prudential Locations; State Board of Land and Natural Resources; Marsh & McLennan, Inc.; Bank of America; Island Insurance Company; Paul Alston; Gensiro Kawamoto; Peter Savio; C. Brewer; Brewer Environmental Services; BEI Hawaii; Maui Home Supply; Everett Dowling; Sports Shinko; R.M. Towill Corp; Park Engineering; Maui Board of Water Supply; Amfac; Alexander & Baldwin (A&B); and Maui Land & Pineapple.
In your letter of October 19th, you also state that you carry professional liability insurance with one of the insurance brokers; however, you do not give the name of the broker. As it is highly relevant to this matter, would you please disclose the name of this broker, as well as the name of the insurance company, or companies, with which this broker has placed your insurance coverages.
Since my letter of October 17th, I have learned of other entities with which you may have some relationship, and I ask that in your response you also describe your relationships, if any, with the following:
Dr. Michael Chun; Ray Fuqua; Ohe`o Stables; Hana Kai Maui Condominium; Kajima Construction; Hawaiian Dredging & Construction Company; General Growth Partners; Helber Hastert & Fee Planners; Hallstrom Group; Group 70 International; Sheraton Maui Resort; Kaanapali Beach Hotel; Geolabs; SSFM International; Atlas Insurance; Micah A. Kane; Milton Pa; John A.H. Tomoso; Charles H. Hurd, Esq.; Crystal Rose; Rockne Freitas; Mahealani Kamauu; Keith Viera; Starwood Hotels & Resorts Worldwide, Inc.; Outrigger Hotels & Resorts.
Thank you very much for your consideration and assistance in this matter.
Bobby N. Harmon
cc: Mary Lou Woo, Trustee, c/o Steven Guttman (via fax @ 808-529-7177)