Bobby N. Harmon, CPCU, ARM
Louisville, Kentucky 40229-1655
December 20, 2003
VIA fax only @ (808) 586-0987
Aon Insurance Managers
205 South King Street, Room 405
Honolulu, HI 96813
RE: Notice of Claim Against Aon Insurance Managers
Ref. Harmon Ch. 7 Bankruptcy Case No 99-04339
Dear Mr. Watanabe:
This is a first Notice of Claim against Aon Insurance Managers (Aon), in their capacity as the captive insurance company manager for P&C Insurance Company, Inc., for bad faith, fraud, racketeering, conspiracy to commit fraud, breach of attorney-client privilege, obstruction of justice, and other wrongful acts.
This claim arises out of Aon’s failure to promptly and properly respond to my initial tender of defense in the referenced case which was originally submitted to Aon Insurance Managers on May 27, 2003. Aon failed to acknowledge receipt of this claim, and apparently failed to submit this claim directly to P&C’s authorized Claims Administrator, John Mullen & Company Inc., for proper assignment and handling by a licensed claims adjuster.
Furthermore, based upon certain, newly-disclosed documents, it is also apparent that Aon Insurance Managers conspired with Clyde Mark, President of P&C Insurance Company; Matt Tsukazaki, Esq., of the law firm of Torkildson Katz Fonseca Moore & Hetherington ; Susan Tius, Esq., of Rush Moore Craven Sutton Morry & Beh; Bradley Tamm, Esq.; Greg Dunn, Esq.; and Steven Guttman, Esq., attorney for Trustee Mary Lou Woo, to wrongfully deny my claim.
In another act of bad faith, Aon also caused a breach in the “China Wall” that should have been erected in this case to prevent disclosure of confidential and attorney-client privileged information to other insured persons who may have coverages under the same liability insurance policy. Due to the obvious conflicts-of-interests involved in this case, I will provide documents evidencing the wrongful acts described herein to only the authorized Claims Administrator for your professional liability insurance carrier.
As arbitration proceedings are currently underway in this case, I ask that you please have the authorized Claims Administrator for this claim contact me as soon as possible.
Very truly yours,
Bobby N. Harmon, CPCU, ARM
cc: Justin W. Schuck, Case Manager, American Arbitration Association
VIA fax only @ 559-490-1919
Trustee Mary Lou Woo,
c/o Steven Guttman, Esq., Kessner Duca Umebayashi Bain & Matsunaga
VIA fax only @ 808-529-7177
J. P. Schmidt, Hawaii Insurance Commissioner
VIA fax only @ 808-586-2806
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