Bobby N. Harmon, CPCU, ARM
August 6, 2004
VIA fax only @ 808-523-6001
Mr. Matt Tsukazaki, Esq.
Torkildson, Katz, Fonseca, Moore & Hetherington
700 Bishop Street, 18th Floor
Honolulu, HI 96813-4187
RE: P&C Insurance Company - Tender of Defense - 74 166 00491 03 JAFA
Mary Lou Woo, Trustee vs. Bobby N. Harmon
Dear Mr. Tsukazaki:
I am enclosing an invoice dated July 18, 2004, from the American Arbitration Association showing an outstanding balance due of $7,550.00. As P&C Insurance Company’s purported attorney in this matter, would you please forward this invoice to P&C’s authorized claims adjuster for payment.
As I stated in my letters to you dated May 26, 2004 and June 17, 2004, if, for any reason, this authorized party is unable to remit payment, I ask that he, or she, respond directly to me, enclosing a copy of any letters of authority and/or claims licenses as may be reasonable to evidence that he/she is legally authorized to refuse to make this payment. As this case basically is a contractual liability claim, any declination of this claim should be properly documented with a Claim Number, the Date of Claim, and a copy of the applicable insurance policy.
I also request that any declination be accompanied by a signed copy of the indemnity agreement between P&C Insurance Company and myself, as its former president. If a signed copy of this agreement has been lost or misplaced in P&C’s office, then you may wish to check with P&C’s attorney Wayne Pitluck, Esq., who drafted and submitted the original incorporation papers. If a signed copy still cannot be located, I ask that the Claims Adjuster for this case obtain and send a copy of the blank agreement that is used for all officers and directors of this corporation.
Due to the lateness of this payment, I ask that the check, and/or a copy of any correspondence, be sent directly to the American Arbitration Association, Attention James B. Farris, Case Manager.
I again request a reply to my letter of March 9, 2004, regarding evidence of your prior and current representations of P&C Insurance Company, Kamehameha Schools Bishop Estate, and any insurance carriers on whose behalf you have acted in these matters. I also request a response to my five-page letter dated June 17, 2004, related to this matter.
Please feel free to contact me if you have any questions. Your immediate response to this urgent matter will be appreciated.
Sincerely,
Bobby N. Harmon
enclosure
cc’s: James B. Farris, American Arbitration Association (via fax @ 559-490-1919)
Steven Guttman, Attorney for Mary Lou Woo (via fax @ 808-529-7177)
Dee Jay Mailer, CEO, Kamehameha Schools (via fax @ 808-523-6313)
Clyde Mark, President, P&C Insurance Co., Inc. (via fax @ 808-523-6313)
Susan Tius, Esq., c/o Rush Moore Craven Sutton Morry & Beh
(via fax @ 808-521-0597)
Gerard Jervis, Lokelani Lindsey, Henry Peters, Oswald Stender, and Richard Wong, c/o Kenneth Hipp, Esq., Marr Hipp Jones & Pepper
(via fax @ 808-536-6700)
Jeffrey H.K. Sia, Esq., Ayabe Chong Nishimoto Sia & Nakamura
(via fax @ 808-526-3491)
Robert S. Tameler, ALPS, Claims Administrator for Bradley Tamm and Greg Dunn (via fax @ 406-728-7416)
Michael F. Perlis, Esq., Stroock & Stroock & Lavan, LLP, Attorney for Federal Insurance Company (via fax @ 310-556-5959)
Lori Chung, Aon Insurance Managers (via fax @ 808-540-4301)
Casimer Fidele, Tradewind Insurance Company (via fax @ 808-521-7489)
Hugh Jones, Deputy Attorney General (via fax @ 808-586-1477)
Governor Linda Lingle, State of Hawaii (via fax @ 808-586-0006)
J.P. Schmidt, Hawaii Insurance Commissioner (via fax @ 808-586-2806)
Janet Hughes, Internal Revenue Service (via fax @ 303-844-3596)
Billy Beaver, Pension & Welfare Benefit Admin. (via fax @ 626-229-1098)
Ralph F. Boyd, Jr., U.S. Dept. of Justice (via fax @ 202-514-1116)
PricewaterhouseCoopers, c/o Warren Price III, Esq. (via fax @ 808-533-0549)
Marsh & McLennan, Honolulu Office (via fax @ 808-585-3510)
Terry Mullen, CEO/Pres., John Mullen & Co. (via fax @ 808-531-0053)
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