Bobby N. Harmon, CPCU, ARM
September 11, 2004
VIA facsimile @ (808)523-6313
Trustee Robert K.U. Kihune
Trustee J. Douglas Ing
Trustee Constance H. Lau
Trustee Diane J. Plotts
Trustee C. Nainoa Thompson
Kamehameha Schools
567 South King Street, Suite 200
Honolulu, Hawaii 96813
RE: Notice of Claim Against the Trustees of Kamehameha Schools, Colleen Wong, Louanne Kam, Maryanne Inouye, Nathan Aipa, Clyde Mark, Rodney Park, their Attorneys and Independent Contractors, et al.
Ref. Harmon Ch. 7 Bankruptcy Case No 99-04339
Dear Trustees:
This is a follow-up to my Notice of Claim sent to you on December 12, 2003, in which I gave you some basic details regarding the reason for the claim, and requested that you report the claim to your insurance carrier and have their authorized Claims Adjuster contact me for further information. To date, I have not been contacted by your insurance company or an authorized Claims Adjuster. During the interim, I have been in contact with your outside attorney, Matt Tsukazaki, of the law firm Torkildson, Katz, Fonseca, Moore & Hetherington. However, this contact has only resulted in further denials, delays and financial losses.
In her latest filing in the referenced bankruptcy case, Trustee Mary Lou Woo is requesting reimbursement of her legal expenses and costs, in addition to substantial penalties against me for my “letter-writing campaign” and for posting certain information on the internet at www.the-catbird-seat.net. I am transmitting to you a copy of my answer to Trustee Woo’s request which is entitled, “Respondent’s Answer to Arbitrator’s Interim Findings of Fact, Conclusions of Law, and Award,” dated September 10, 2004.
Accompanying Mary Lou Woo’s request was an itemized list of fees entitled, “Declaration of Steven Guttman in Support of Claimant’s Request for Attorneys’ Fees and Costs,” dated September 2, 2004. I have not included a copy of this list as it is over fifty pages long; however, you will find excerpts from this filing in the enclosed Answer. The total amount being requested is $57,020.53.
A large percentage of the total charges in this billing resulted from conferences, telephone calls, and e-mails between the Trustee’s attorney, Steven Guttman, Esq., of Kessner, Duca, Umebayashi, Bain & Matsunaga, and attorneys Matt Tsukazaki, Colleen Wong, Louanne Kam and Susan Tius. There are also listed conferences between Guttman’s office and John Mullen & Co., the independent claims adjuster for your captive insurance subsidiary, P&C Insurance Company, Inc. There is even listed a phone call from Master Benjamin Matsubara.
Due to the large number of entries, I have not had a chance to calculate the total costs that can be attributed to the communications between Steven Guttman and your attorneys and claims administrator, but I would estimate that it would comprise over half the total costs. If you will have your independent claims adjuster for this claim contact me, I will send him a complete copy of Mr. Guttman’s expenses.
Thank you for your prompt attention to this urgent matter.
Very truly yours,
Bobby N. Harmon
encl.
References:
References:
www.the-catbird-seat.net/BK-Objection-1-19-5.htm
www.the-catbird-seat.net/AAA-Dec-SG-re-fees.pdf
www.the-catbird-seat.net/AAA-Guttman-Att-A.pdf
www.the-catbird-seat.net/AAA-Guttman-Att-B.pdf
www.the-catbird-seat.net/AAA-Guttman-Att-C.pdf
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