Bobby N. Harmon, CPCU, ARM




January 8, 2003

VIA Fax @ (808) 523-6001 & U.S. Postal Service


Matt A. Tsukazaki, Esq.

Torkildson, Katz, Fonseca, Jaffe, Moore & Hetherington

700 Bishop Street, 15th Floor

Honolulu, HI 96813-4187

 

RE:    Kamehameha Schools and P&C Insurance Company

          Forms W-2 and 1099-R for 2000; Taxpayer ID ; SS#


Dear Mr. Tsukazaki:


This is to inform you that it has been over 60 days since my letter of November 4, 2002, addressed to Kamehameha Schools regarding the issuance of the required IRS Forms W-2 and 1099-R for the year 2000, and that, as in the case of previous letters, there has been no response.


As the obligation for these forms arose out of the settlement of an insurance claim, I wish to point out to you, and to the claims administrators, the following requirements as stated in articles of the Hawaii Insurance Statutes (Section 431: 13-101 through 107):


UNFAIR CLAIM SETTLEMENT PRACTICES


... Committing or performing with such frequency as to indicate a general business practice any of the following:


... failing to respond with reasonable promptness, in no case more than fifteen working days, to communications with respect to claims arising under its policies;


... failing to adopt and implement reasonable standards for the prompt investigation of claims;


... not attempting in good faith to effectuate prompt, fair, and equitable settlements of claims;


... compelling insureds to institute litigation to recover amounts due under an insurance policy by offering substantially less than the amounts ultimately recovered in actions brought by the insureds.


In my case, the Settlement was reached in the year 2000; however, I have never received an accounting of the withholding or payment of the required Social Security taxes (Form W-2), or of any adjustment in my Kamehameha Schools Retirement Plan (Form 1099-R). As the entire settlement amount was to be characterized as “Wage Income”, I consider the failure to properly withhold and pay the Social Security taxes, and the failure to contribute whatever amount was due to the Kamehameha Schools’ Retirement Plan, to be material breaches of the Settlement Agreement. In addition, as this case involved insurance policies issued by Federal Insurance Company and P&C Insurance Company, with the agent or broker being Marsh & McLennan, I am of the opinion that the above quoted Hawaii Statutes would apply.


Therefore, I am again requesting the proper issuance of IRS Forms W-2 and 1099 for the year 2000, in order that I may receive the full amounts due under the Settlement Agreement. If Kamehameha Schools and/or the insurance companies are declining to pay these Social Security taxes and contribute additional monies due the Retirement Plan, then I respectfully request an explanation from them, or from their legal representative, for their refusal to render these payments.


Furthermore, if your law firm disclaims any responsibility for these claims, then I request that you advise me of the proper party to whom I should address future correspondence.


Very truly yours,




Bobby N. Harmon

 

cc’s:  Mr. Ray Blanchard, Operations Manager, AUR

Internal Revenue Service

Ogden, UT 84201

 

Janet S. Hughes, Mgr., Employee Plans & Exempt Organizations, IRS

VIA fax @ 303-844-3596

 

Debra Sakai, Hawaii State Tax Collector

VIA fax @ (808) 587-1720

 

Billy Beaver, Pension & Welfare Benefit Administration

VIA fax @ 626-229-1098

 

Attorney General Mark Bennett, State of Hawaii

VIA fax @ 808-586-1239

 

Dr. Randy Roth, Office of the Governor, State of Hawaii

VIA fax @ 808-956-5569

 

Benjamin M. Matsubara, Esq.

Kamehameha Schools Master

888 Mililani St., 8th Floor

Honolulu, HI 96813-2918

 

Insurance Commissioner, State of Hawaii

P.O. Box 3614

Honolulu, HI 96811

 

XL Insurance Company, Ltd., Claims Dept.

VIA fax @ (441) 295-7524

 

Hamilton McCubbin, CEO, Kamehameha Schools

c/o Susan Tius, Esq., Rush Moore Craven Sutton Morry & Beh

VIA fax @ 808-521-0597

 

P&C Insurance Company, Inc., c/o Aon Insurance Managers

VIA fax @ 808-540-4301

 

P&C Insurance Company., Inc., c/o Ayabe Chong Nishimoto Sia & Nakamura

VIA fax @ 808-526-3491

 

Federal Insurance Company, Claims Department, Attn. Michael Goolsby

(213) 833-5200

 

Marsh & McLennan Companies, Inc., c/o Robert F. Miller, Esq.

735 Bishop Street, Suite 320

Honolulu, HI 96813

 

Marsh Management Services, Inc.

VIA fax @ 808-585-3513

 

John Mullen & Co., c/o James V. Myhre, Esq.

VIA fax @ 808-524-2556

 

Kamehameha Schools, c/o Melvyn M. Miyagi, Esq., Miyagi, Nohr & Myhre

VIA fax @ 808-524-2556

 

Robert Katz, Atty. for Torkildson, Katz, Fonseca, Jaffe, Moore & Hetherington

VIA fax @ 808-523-6001

 

Kenneth B. Hipp, Esq., Marr, Hipp, Jones & Pepper

VIA fax @ 808-536-6700

 

PricewaterhouseCoopers, LLP, c/o Warren Price, III

(VIA fax @ 808-533-0549)

 

T.M. Kittredge, Esq., Morgan, Lewis & Bockius

VIA fax @ 215-963-5299

 

Miller & Chevalier

VIA fax @ 202-628-0858

 

Mary Lou Woo, Trustee, c/o Steven Guttman, Esq.

VIA fax @ 808-529-7177

 

John Goemans, Esq.

VIA fax @ 808-887-1099

 

Arnold T. Phillips, Esq.

VIA fax @ 808-528-5006

 

Roy F. Hughes, Esq.

VIA fax @ 808-521-7489

 

Bradley R. Tamm, Esq.

VIA fax @ 808-524-4844

 

Mr. Cliff Rones, Esq., U.S. Dept. of Justice, Criminal Div., Fraud Section

VIA fax @ 202-514-7021

 

Mr. Tai K. Lee, Special Agent, U.S. Dept. of the Treasury

VIA fax @ 808-539-2810


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