Bobby N. Harmon, CPCU, ARM
Louisville, Kentucky 40229-1655
January 28, 2004
VIA fax @ 808-523-6313
& Certified Mail
Mr. Clyde Mark, President
P&C Insurance Company, Inc.
c/o Kamehameha Schools
567 South King Street
Honolulu, HI 96813
RE: Mary Lou Woo, Trustee vs. Bobby N. Harmon
Demand for Arbitration - 74 166 00491 03 JUSC
Dear Mr. Mark:
On May 27, 2003, I tendered defense of the above claim to P&C Insurance Company, Inc., c/o Jill Miura of Aon Insurance Managers. In a letter dated January 22, 2004, Aon’s Lori Chung advised that their captive management contract with P&C was terminated on June 30, 2003, and asked that I contact P&C or Kamehameha Schools for information regarding your new captive manager.
Since the date of my original tender, I have sent follow-up letters regarding this case to Aon as well as to you; Matt Tsukazaki of Torkildson Katz Fonseca Jaffe Moore & Hetherington; and Terry Mullen of John Mullen & Co. Although I did receive a denial of this claim from you, by means of your letter dated June 20, 2003, as I pointed out in my reply of June 30, 2003, I did not consider this a legitimate rejection of my claim for a number of reasons. Rather than repeat these reasons here, or sending you copies of all my letters, I am enclosing a copy of my letter dated July 28, 2003, to P&C Insurance Company, c/o Aon Insurance Managers, which summarizes much of my correspondence up to that date.
There have been a number of letters since that date; however, these letters have been directed to Aon, Matt Tsukazaki, or John Mullen & Co. for various reasons. You may wish to check with them for further information.
As Aon Insurance Managers failed to respond to my previous letters and neglected to advise me that their agreement with P&C was terminated back in June 30, 2003, I am directing this follow-up letter to you for your assistance.
To bring you up to date regarding the status of the subject claim, there is currently a payment of $2,525.00 due to the American Arbitration Association. A copy of their invoice is enclosed. The Claimant has scheduled taking deposition upon oral examination on February 10 and 11, 2004, in Louisville, Kentucky.
Due to the time-frame and urgency of this matter, I ask that you please have P&C’s current Captive Manager and/or Claims Administrator contact me immediately for further details.
Thank you very much for your assistance.
Sincerely,
Bobby N. Harmon
enclosures
cc’s: Justin Schuck, American Arbitration Association (via fax only @ 559-490-1919)
Steven Guttman, Atty for Mary Lou Woo (via fax only @ 808-529-7177)
Robert Kihune, Douglas Ing, Constance Lau, Diane Plotts, Nainoa Thompson,
Trustees of Kamehameha Schools (via fax only @ 808-523-6313)
Dee Jay Mailer, CEO, Kamehameha Schools (via fax only @ 808-523-6313)
Casimer Fidele, Tradewind Insurance Company (via fax only @ 808-521-7489)
Hugh Jones, Deputy Attorney General (via fax only @ 808-586-1239)
Dr. Randy Roth, Office of the Governor (via fax only @ 808-586-0006)
J.P. Schmidt, Hawaii Insurance Commissioner (via fax only @ 808-586-2806)
Janet Hughes, Internal Revenue Service (via fax only @ 303-844-3596)
Billy Beaver, Pension & Welfare Benefit Admin. (via fax only @ 626-229-1098)
Miller & Chevalier (via fax only @ 202-628-0858)
Morgan, Lewis & Bockius, Attn: T.M. Kittredge, Esq. (via fax @ 215-963-5299)
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