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State Farm auto-parts trial documents

Editor's note: The following memos are verbatim copies of State Farm's internal documents that were entered as evidence in the auto-parts class action lawsuit in Marion, Ill. On Oct. 4, a jury found State Farm guilty of breaching its contract with its policyholders and awarded $456 million to the plaintiffs. On Oct. 8, Judge John Speroni ordered State Farm to pay an additional $730 million in damages.

Bird, Samantha F. / GRLY/38- HPDESK Print.

Message Dated: 04/06/90 at 1504.

Subject: PURGNG OLD FILES Contents: 2

Sender: Samantha F. Bird/ GRYL/38

Cc: Samantha F. Bird/ GRYL/38

Part 1.

To: Clark Davis /GRYL/38
Marcia Daybell/GRYL/38
Felix Jensen/GRYL/38
Susan E. More/GRYL/38
Jerry L. Stevenson/GRYL/04
Paul L. West/GRYL/38
Carol J. Young/GRYL/38

CC: Samantha F. Bird/GRYL/38
Robert Dean Noxon/GRYL/38

Part 2.

Yesterday in the staff meeting, we talked about the need to purge our desks of all old memo's, notes and procedural guides. With the increase of bad faith suits bieng filed against State Farm, it is important that you get rid of all your old stuff: Know you have lurking around in your drawers and filing cabinets.

Please get rid of any old memo's, claim school notes, old seminar or claim conference notes, and any old procedure guides you may have. They are trying to avoid having to come up with old records when the "request for production of documents" comes in and they request "all training manuals, memos, procedural guides, etc. that are in the possession of your claims reps and management". Apparantly, they had a request like this in Texas and each person had to surrender all their old junk. I guess corporate is not even going to keep old CPG guides, old claim manuals, etc. We will only have what is currently in effect. That way if they subpoena our claim manual for U claims for 1987, for example, we will say we dont have it. This should be easier than trying to produce it or having to defend it.

So, look through all your old stuff and dump it. You wont ever miss it.

Also we discussed that every employee has the right to look at his or her personnel file without recrimination. There should be nothing in your personnel file that you dont already have a copy of. But if you feel the need to see something in your file, it is open to you.

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