state of michigan circuit court for the 30th judicial ... · 30/05/2018 · priority under mcl...

STATE OF MICHIGAN CIRCUIT COURT FOR THE 30TH JUDICIAL CIRCUIT

INGHAM COUNTY

R. KEVIN CLINTON, COMMISSIONER OF THE OFFICE OF FINANCIAL AND INSURANCE REGULATION,

Case No. 12-1173-CR Petitioner,

V

AMERICAN FELLOWSHIP MUTUAL INSURANCE COMPANY,

Respondent.

Christopher L. Kerr (P57131) M. Elizabeth Lippitt (P70373) Assistant Attorneys General Attorneys for Petitioner Corporate Oversight Division P. 0. Box 30755 Lansing, MI 48909 (517) 373-1160 ________________ /

HON. WILLIAM E. COLLETTE

[IN LIQUIDATION]

PETITION FOR COURT ADJUDICATION OF CLAIMS DETERMINATION DISPUTE

Patrick M. McPharlin, Director of the Michigan Department of Insurance and

Financial Services ("DIFS"), 1 as Liquidator of American Fellowship Mutual

Insurance Company (the "Liquidator"), by and through his attorneys, Bill Schuette,

1 Pursuant to Executive Order No. 2013-1 effective March 18, 2013, the Michigan Office of Financial and Insurance Regulation ("OFIR") was renamed the Michigan Department of Insurance and Financial Services ("DIFS") and all the authority, powers, duties, functions, and responsibilities of the former Commissioner of O FIR were transferred to the newly-created position of the Director of DIFS. Governor Snyder duly appointed Patrick M. McPharlin as the Director of DIFS effective May 18, 2015, making him the Liquidator of American Fellowship as of that date.

Attorney General, and Christopher L. Kerr and M. Elizabeth Lippitt, Assistant

Attorneys General, petitions this Court pursuant to MCL 500,8139(2) to adjudicate

the claims determination dispute raised by claimant Liberty Claim Services, LLC

("Liberty") through its owner, Lester "Bud" O'Brien ("Mr. O'Brien"), regarding

Liberty's two Proofs of Claim filed in the ongoing liquidation proceeding of

American Fellowship Mutual Insurance Company ("American Fellowship"). In

support of this Petition, the Liquidator states as follows:

1. On October 29, 2012, this Court entered an Order placing American

Fellowship into rehabilitation, appointing the DIFS Director as Rehabilitator of

American Fellowship (the "Rehabilitator"), and approving the Rehabilitator's

appointment of James Gerber as Special Deputy Rehabilitator of American

Fellowship (the "Rehabilitation Order'').

2. On June 12, 2013, this Court entered an Order converting the

rehabilitation of American Fellowship to a liquidation, which likewise appointed the

DIFS Director as Liquidator and approved the Liquidator's appointment of James

Gerber as Special Deputy Liquidator of American Fellowship (the "Liquidation

Order").

3. Pursuant.to the Liquidation Order and MCL 500.8121(1)(a), Special

Deputy Liquidator James Gerber (the "Deputy Liquidator") possesses "all the

powers of the Liquidator granted under Chapter 81 of the Insurance Code, subject

to the supervision and direction of the Liquidator and this Court."

2

4. The Liquidation Order established a claim deadline of six (6) months

after its entry date-or December 12, 2013-by which any claimant asserting a

claim against the assets of American Fellowship's liquidation estate was required to

file a proof of claim conforming with the requirements of MCL 500.8136 and other

applicable provisions of Chapter 81 of the Michigan Insurance Code ("Insurance

Code").

5. Together with a letter dated December 6, 2013, which the Deputy

Liquidator and his staff received on December 26, 2013, Liberty filed two proofs of

claim against American Fellowship for "fees and expenses" relating to claim

adjusting services provided to American Fellowship during the years 2006 to 2008

in the total amount of $49,679.51. (Exhibit 1, Liberty Letter and Proofs of Claim

dated 12/6/13.)

6. In a letter dated April 14, 2016, the Deputy Liquidator notified Liberty

that its Proofs of Claim were classified as Class 5 (general creditor) claims under

Section 8142 of the Insurance Code, MCL 500.8142. (Exhibit 2, Letter from

American Fellowship to Liberty dated 4/14/16.) The letter further advised Liberty

that its Class 5 claims would not receive any distributions from the assets of

American Fellowship's liquidation estate because MCL 500.8142(1) requires every

claim in each higher priority class (i.e., Classes 1 through 4) to be paid in full before

members of the next class receive payment and the estate would have insufficient

assets to pay any creditors past the Class 2 priority level. (Id.)

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7. Liberty responded by letter dated May 13, 2016, in which it: (a)

disputed the Class 5 payment priority assigned to its Proofs of Claim; (b) asserted

that Liberty and/or its owner Mr. O'Brien were direct employees of American

Fellowship; and (c) alleged that various legal claims and doctrines should elevate

Liberty's Proofs of Claim to absolute top priority payment status over the claims of

all other creditors, despite the clear mandates ofMCL 500.8142. (Exhibit 3, Letter

from Liberty to American Fellowship dated 5/13/16.)

8. The Deputy Liquidator replied in a letter dated June 21, 2016.

(Exhibit 4, Letter from American Fellowship to Liberty dated 6/21116.) Among

other things, the Deputy Liquidator's letter:

• Formally notified Liberty that after reviewing its Proofs of Claim for the total amount of $49,679.51, it was determined that the allowed amount was only $33,547.60 because the remainder was time-barred by the applicable 6-year statute of limitations.

• Reaffirmed that this allowed amount of Liberty's claim was properly classified as a general creditor claim accorded Class 5 distribution priority under MCL 500.8142(1)(e), because Liberty was a third-party contractor and there was no evidence to support any direct employment relationship with American Fellowship.

• Explained that even assuming a direct employment relationship, the limitations on employee claims for services under MCL 500.8142(l)(a) and (d) precluded Liberty's claim from receiving elevated Class l or Class 4 priority so it would remain a Class 5 general creditor claim.

• Reiterated that the American Fellowship liquidation estate would not have sufficient assets to pay creditors beyond the Class 2 priority level, meaning there would be no distributions to Liberty on the allowed portion of its claim.

• Advised Liberty of its right to file written objections to the letter's claim determination within 60 days, pursuant to MCL 500.8139(1). [Id.]

4

9. On August 16, 2016, Liberty filed written objections to the Deputy

Liquidator's June 21, 2016 letter. (Exhibit 5, Letter from Liberty to American

Fellowship dated 8/16/2016.) Again, Liberty's objections focused on the Class 5

payment priority assigned to its claims, repeating similar arguments from its

earlier May 13, 2016 letter about why its claim was "superior" and should receive

elevated payment priority ahead of all other creditors. (Id.) In addition, Liberty

objected to the reduction in the allowed amount of its claim based on the applicable

6-year statute oflimitations. (Id. at pp 1-2.) Barring the parties' ability to resolve

these disputes, Liberty's letter requested that the matter be submitted to this Court

for resolution. (Id. at p L)

10. Section 8139 of the Insurance Code, MCL 500.8139, governs the

process for resolving disputes involving the Liquidator's denial of a claim:2

(1) If a claim is denied in. whole or in part by the liquidator, written notice of the determination shall be given to the claimant or his or her attorney by first-class mail at the address shown in the proof of claim. Within 60 days from the mailing of the notice, the claimant may file his or her objections with the liquidator. If a filing of objection is not made, the claimant shall not further object to the determination.

(2) If objections are filed with the liquidator and the liquidator does not alter his or her denial of the claim as a result of the objections, the liquidator shall ask the court for a hearing as soon as practicable and

2 The statute only expressly addresses a claimant's ability to object to "a claim [being] denied in whole or in part by the liquidator," or in other words, the liquidator's determination about the amount of the claim allowed, if any. The statute does not state whether a claimant can also object to the payment priority the liquidator assigns to a claim, which is independently governed by MCL 500.8142. However, to ensure a full and final decision on all issues, and without waiving his ability to argue that the statute precludes payment priority objections, the Liquidator submits all of Liberty's objections for this Court's review including those relating to its claims being assigned Class 5 payment priority.

5

shall give notice of the hearing by first-class mail to the claimant or his or her attorney and to any other persons directly affected, not less than 10 nor more than 30 days before the date of the hearing. The matter may be heard by the court or by a court appointed referee who shall submit findings of fact along with his or her recommendation. ·

11. As noted, the Deputy Liquidator and Liberty have exchanged

numerous letters and had several discussions concerning this dispute. The Deputy

Liquidator has also reviewed Liberty's August 16, 2016 written objections and

reexamined all relevant evidence and legal authority supporting the determinations

made in his June 21, 2016 letter regarding Liberty's Proofs of Claim. The

Liquidator and Deputy Liquidator remain confident that these determinations are

legally and factually correct, and therefore are not altering them pursuant to MCL

500.8139(2) as a result of Liberty's objections. Any settlement at this juncture is

also highly unlikely. Accordingly, the Liquidator now submits this dispute to the

Court for its review and final decision.

12. Because this dispute involves legal questions of statutory

interpretation and no genuine issues of material fact, it is capable of decision on

written motion(s) for summary disposition under MCR 2.116(C)(8) and (10).

Consequently, the Liquidator requests that the Court enter the proposed order

attached as Exhibit 6, which grants the Petition, sets a schedule for briefing and

oral argument, and establishes certain other procedures governing the Court's

adjudication of this dispute.

6

WHEREFORE, for the reasons stated above, the Liquidator respectfully

requests the Court to grant this Petition for Court Adjudication of Claims

Determination Dispute and to enter the proposed order attached as Exhibit 6.

Dated: May 30, 2018

7

Respectfully submitted,

Bill Schuette Attorney General

Christopher L. Kerr (P57131) M. Elizabeth Lippitt (P70373) Assistant Attorneys General Attorneys for Petitioner Corporate Oversight Division P. 0. Box 30755 Lansing, MI 48909 (517) 373-1160

E X ,, ', " ~ - .- "

H I B I T

1

December 6, 20i3

Mr. James Gerber

LIBERTY CLAJM SERVICES LLC P .0. BOX 2064

BRIGIITON, MIClllGAN 48114 ph 810-599-1771

Via Registered Mail

American Fellowship Mutual lnsurance 25925 TelegraphRoad Suite 200 i,

Southfield, Michigan 48033

; . · Re: Proof of Claim American FeHowsbip Liquidation •_ C >

Dear Mr. Gerber:

Please find enclosed two separate completed Proof of Claim forms relative to the. outstanding service fees and. expenses owed to Liberty Claim Services, LLC /Lester Bud O'Brien by American FeHowsbip Mutual Insurance Company. Additionally find enclosed the following; ·

a. an inventory page identifying the rurme of 1lie policyholder upon which the services were provided, the amount of the service fees and incurred expenses and whether the Appoin1ment was made as an Appraiser because of the dispute of damages between American Fellowship and its policyholder or as a full claim handling assignment;

b. an itemized invoice of each claim serviced with the policyholder's name, policy and claim number if known, and the date of the claimed loss;

c. Claim log historical data identifying LCS/Lester Bud O'Brien's initial claim receipt along with the activity and date performed;

I look forward to hearing from you as to approval and payment of our service fees and expenses.

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This packaging Is the property of tho U.S. Postal Ser.vice® and Is provided, solely for use In sendlng)''.rlorl Mls!J$O may be a violation of foe/era/ law, T/1/s packaging is not for resale, E!P14 !I: U.S. Postal Se'rviaa; Jl!JJ

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AMERICAN FELLOWSHIP MUTUAL PROOF OF CL.AIIVt FORM 0092f I~ Deadline for filing:

DEC 2 6 2013 Please read carefolly before completing this form. Each section must be fully completed. Instructions are attached, If additional copies are needed, please photocopy or download the Form at: www.michigan.gov/difs ·then click "Who We Regulate'\ then .American Fellowship, then "Proof of Claim Form". File a sepa:rate "Proof of Claim" form fol' each unrelated claiitl.

FOR OFFICE Us;E'ONLY Date Postmarked: . Part 1: CLAIMANT INFORMATION

Addres::rl: Lester Bud O'Brien *** A'.1dress 2: p. o .• Box 2 0 6 4 Continue

C1ty:Brightpn, State: Michig Zip Code: 4 B 1 1 4 Country:

Proof of Claim Number: Date Received:

i{elephone Number Home: Work: O

Does an attorney represent you? Yes ( ) No ( x ) - ff yes, provide attorney's name., address & telephone number:

Part 2: INSURED /POLICY INFORMATION N~e of Insured: Pdticy Number: A ent Name or Number: Part 3: CLAIM INFORMATION

· ant/Patient: . Number:

Date of Loss:

Amount of Claim: ~ ------+----------tn=-:e--¥Flft-'1-¥+al'te-:H bill ck the statement e ow at besi describes

our claim: POLICYHOLDER OR THIRD PARTY CLAIM Claim by insured for POLICY BENEFITS or claim against an insured for POLICY BENEFITS ..

RETURN OF UNEARNED PREMIUM OR OTHER PREMIUM REFUNDS Portion of paid premium not earned due to early cancellation of policy or audit adjustment

POLlCYHOLDBR COLLATERAL

CREDITOR Agents, Attomey fees, Vendors, Landlords, Lessors, Consult.ants~ Cedi:ints and Reinsurers

ALL OTHER Dest:ribe:

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1-=--------,-=c--=occm:=l='-'NUED""•=-O"-'N'-'-"'REVERS=-c.==E~SID==E~------'-'---~--"C-"f, 2;-r l/ Do you owe any money to the Company? If yes, specify the amount:$ DEC 2 ,, ,

0.13 And the reason: "'

No Is this a secured claim? If yes, specify all security for such claim:

As to this claim Liberty Claims Services,LLC has a Third Party Beneficiary Claim, as ,l\:merican Fellowship ***

· Is this claim contingent or unliquidated? If yes, specify the reason:

No Part 4: AFFIRMATION

PROOF OF CLAIM AMERICANFELLOWSIDPMOTUAL JNSURANCE COMPANY

Irr Liquidation (fue "Company") Ingham County Circuit Court, State of Michigan; Case No. 12-1173-CR

The undersigned subscn'bes and affinns as true under the penalties of perjury as follows: that he or she has read the foregoing Proof of Claim and knows the contents thereof; that this claim in

, total amount of$ 1.:Z , 3 i§. S ~st the Company is justly owing to the Claimant; that the · matters set forth and in any accompanying statements and supporting documents are true ·and

correct; that no payment of or on account of the aforesaid claim has been :received except all

above stated; and that there are no setoffs or counreril· · ms thereto except as ab stated, I , /ltf.v~M;,t,

~ It, Le,

Title or Official Capacity (if any)

Claimants Attorney (if applicable)

IMPORTANT NOTICES A. Proof of Claim nrust be properly sigoed and dated, Remember to attach all dooumeotation. · B, Deadline for filing Proof of Claims is December 12, 2013, C, If you have a change of address, you are required to inform the Liquidator at 1he address below of the new address in order to receive any payment that might be due. D, Return your completed form to:

American Fellowship Mntual Suite 200 25925 Telegraph Road Southfield, :t,1148033

E-Mail: Fax: (248)-352-4921 Phone; l-(800)-648-6329

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DEC 2 6 201l

AMERICAN FELLOWSHIP MUTUAL JNSURANCE COMPANY PROOF OF CLA.lM FORM

RESPONSE CONTINUATION

Page 1 Part 1 Claimant Information (Person Making Claim):

Address 2:

Page 1 Part 3 'Claim Information:

-Question:· Check the statement below that best describes your claim: ·' -

Policyholder or Third Party Claim: . LCS/Lester Bud O'Brien is a Third Party Beneficiary on all Appointments as American Fellowship's Selected Appraiser on Claim Damages under dispute; wherein the American Fellowship issued policy involved in the disputed claim · requires payment by American Fellowship to its selected Appraiser; see policy Appraisal Provision language.

. Question: Describe the basis· and nature of the claim ...... .

Whereas, American Fellowship was aware that Liberty Claim Services/ Lester Bud . . O'Brien was an experience insurance Professional and believed that it was beneficial to have available to it, LCS / Lester Bud O'Bi;ien extensive knowledge and experience concerning the adjustment of Property and Casualty Claims and as . _ .American Fellowship's appointed Appraiser .relative to damage disputes with · claimants, its policyholders, according to the Appraisal provision of the Policy.

Whereas, American.Fellowship Mutual desired to engage in~a ~ontinuous claim consul.ting relationship with LCS/Lester Bud O'Brien for specific operations of its business and requested that LCS be available to AFM, for investigation. activities, damage assessments including appraisal appointm~ts, advice, claim negotiations, settlements, and expertise.

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DEC 2 6 2il13 AMERICAN FELLOWSHIP MUTUAL INSURANCE COMPANY PROOF

OF CLAlMFORM


Whereas, American Fellowship Mutual agreed to pay LCS/Lester Bud O'Brien and hourly service-fee and the reimbursements of expenses, upon receipt from LCS / Lester Bud O'Brien supporting documentation including all those reasonable, appropriate and necessary business expenses associated and incurred as a direct relationship and resulting from the performance ofLCS/Lester Bud O'Brien's cbtim services to and for American Fellowship Mutual.

_ Whereas; there has been continuous representation provided to American ·:Fellowship and its policyholders by LCS/Lester Bud O'Brien for approximately 10 years through February 2009.

Question: Has a lawsuit or other legal action been, instituted by anyone regarding this claim? The lawsuit was dismissed without prejudice on June 25, 2013.

Question is this a: Secured Claim? Yes, as LCS / Lester Bud O'Brien have a Third Party Beneficiary claim as American Fellowship retained LCS/Lester Bud O'Brien as their Selected Appraiser and the Policy Appraisal provision obligates payment from American Fellowship to their appointed Appraiser, see the policy Appraisal conditions.

LCS / Lester Bud O'Brien expressly reserve the right to amend and supplement the Proof of Claim.

Page4

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1 2 3 4 5 6

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Name

• -collection fees

,,

I •

1

00921: ~

DEC .2 6 2013

amount Appointed American Fellowship Appraiser

$1,822,62 *** $4,364.00 .*** $5,581,46 .....

$103.01 *** $61.46 ***

$393.98 $12,326.53 !

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.. .. B.1,P,:TQ . . . .

American Fellowship 26001 Telegraph Rd Southfield, Michigan 48034 Attn Trevor Miles

---; ..

ITEM .. ·•-·

Property Loss

mileage phone

,,

•• Claim No: Date of Loss: 1 5/2004

. . .

office miscellaneous copies, binders, overnight mailing

Thank you for your business!

' ,. .. ..

Kc 2 s 2013

DA.TE

11/23/12

,· . .... --~ .: . ,SHI.P.T(? . . ~' . .. ..

Liberty Claim Services, LLC P. o. Box 2064 Brighton, Michigan 48114

l •

:

009211 I!

1riVt>"ice ·_ . lNYl?!.c~ it

.. ---.. ... . -

11531

. . -. ._; , ..

Phone No 810.227-0517 or 810.599-1771

.. .. ..

-· oui;·:.of\TE P.,o. NU"¥,BEff· ·.

' ·QTY

28.17

Subtotal

0%Tax

60

12/23/12

~RJ:ITE 51.50

0.42

. - .AMOUNT-"· .. '

1,450.76

25.20 17.50

253.44 75.72

1,822.62

'TotaJ ,, __ -· -· -- .. . .. . -.= ··;·:·-.. .. .. . . ;~,-82_?;~?.

:-.- ....

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'

·1 .Adjuster Insured Claimant I Claim.No.

Policy No. I :bate of~oss

I •

Bud=;;::q·;oi~: ~-~~· ,,~~:f;L.~r

-· 12/15/2004

Mileage (.42/Mile)

Pictures @ 2.25/pictute

copy material, binders,

and overnight mailing to umpire

51.50

60 Mileage Cost 25.20 Phone Cost 17.50

Office Cost 253.44 0 Picture Cost 0,00

Misc, Cost 75.72

I 0092f

·1· Date Tune (nrins)

I 11/10/2006

11/28/2006

I 4/11/2007

4/11/2007 -;-

I ·~ ·•

4/12/2007

I 4/12/2007

9/26/2007

I 9/27/7.007 ·

9/29/2007

9/29/2009

I . 10/2/2007

10/2/2007

I 10/3/2007

10/5/2007

10/6/2007

I 10/10/2007

10/11/2007

I 10/12/2007

10/13/2007

I 10/15/2007

I 10/16/2007

10/16/2007

I 10/16/2007

I 10/i6/2007

I

Action Taken

15 ~ up & review new assignment.

30, prepare correspondence to appraiser JeffMoss

10 phone conversation with Jeff Moss

10 phone converslrtion with Trevor Miles

Gross Total

0 advised that we spoke with the insu:red's appraiser who indicated th.at a petition was

O filed with th.e court

10 checked with Oakland Court Circuit Court no petition filed could be in another court

30 prepared correspondence to Trevor Miles and 1he insured's Appraiser Jeff Moss

60 review materials from insured appraiser

15 phone conversation with Trevor Miles

15 phone call to Best West:emon type ofrooms leased

60 review file materials frQlll. other appraiser

90 meeting with Trevor Miles

135 reviewed file in preparation of report to Trevor Miles

10 phone converswon with Mark Frankel Umpire

20 correspondence to Umpire Mark Frankel

120 reviewreceipts food, motel, ale expenses sumbitted

60 review file for report to umpire

120 review file :in preparation of report to Umpire

20 prepared con-espondence to Umpire

330 reviewed file :in prepw:a.tlon of appraisal assessment wi1h enclosur~s

0 to Umpire; ALE llll{.terials, checks, correspondence between co & Pa. building estimates . . 0 and personal property ~ords

30 review policy information sent~ umpire advised we would geHi.ppicable dee page

10 phone conversation -with Temporary Housing on apt,house monthly rent quote·

0 furnished

10 phone conversation with. Housing Headquarters .on apt/ house rental for 90 days

0 and then month to month furnished for the time period following ibis fire

5 phone call to Trevor Miles advised wrong dee page & expl on payment

0 of $25,000 and itemized notatlon indicates $14,0QO

15 phone conversation with Trevor Miles regarding the dee page and Af

0 explanation of a $25,117 ALE payment and the itemization is fur $14,348.88

0 did.American Fellowship intend on paying for the closing costs & the cost associated with the

$1,822.62

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10il7/2007

10/19/2007

10122.!2007

10.!2512007

11/7/2007

11/7.!2007

11/712001

ll/8.!2007

11/9/2007

12/12/2007

12/13/2007

I 12/18/2007

12/18/2007

I 12129(2007

1/3/2008

I 1/7/2008

I 2/7f2008

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0 sale of the home Trevor said no he will review and get back with me,

IO fax document from Temp Housing

10 pbone conversation with Norn at CRS about getting quotes on rentals

15 phone conversation with CRS regarding rental quotes ' 20 reviewed file in preparation of correspondence to the umpire

20 reply to umpire on apt

20 prepared correspondence to Trevot Miles

10 phone conversation wi1h Trevor MIies he does not believe he needs to attend

15 reviewfile:in preparation of meeting on l 119 ,

130 trawl to office of Umpire, appraisal assessment discussion

0092f ~

DEC 2 s 20!3

30 review correspondence from Frankel & provided an acknowledgement of onr receipt

15 phone conversation with Trevor Miles and Dan Zolkower

45 review file & prepared correspondence to UmpireMBik Frankel

15, email correspondence to Umpire

45 reviewed file & prepared correspondence to Umpire Mark Frankel

10 phone call tc Mark Frankel he will send out con:fumation of1he award & a signature

0 page

45 reviewed file & prepared correspondence to Umpire Mark Frankel will! cc to appraiser

0 for :inmlred & American Fellowship

5 phone call lo atty FtaJJkel )eft message

1690

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- -- . ·- ... :· ' . : B!L!-'·TC>:" .. .. . , •:_ . . -American Fellowship 26001 Telegraph Rd Southfield, Michigan 48034 Attn Trevor Miles

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~-- . .

-- ·. ~M . · · . -· · ·· . _- _· · > , .. _\~ :: : : '.-_: . .-- D)=,sai1~!!C?N . '_. · : Property Loss

mileage phone office photographs

ClalmNo·III Polley No: Date of Loss: 4f//2007

including transcribed statement


..

. ·oATE-. : ·- ... ~· .

11123/12

······ -'·.·:SHIP TO ··.- . .. -· •• 0 •• M

Liberty Claim Services, LLC P.O. Box 2064 Brighton, Michigan 48114 Phone: 810-~7-0517 or 810-599-1771

---1:)UE DATE: . .. .....

66.16

350

140

Subtotal

0%Tax

12/23/12

' .. ·-

51.50

0.42

225

Total· .--_ --.-·:· ·.- ---, : •:MO•

•• 1, •••

· INVOICE.# : · _. .. ,. . . . . . ' . . ..

11532

.. ·' - .. . .. :

3,407.24

147.00 22.80

471.96 315.00

4,364.00

. _. ... : ... :. :4_;364'.00 . .. -.~. . ·: . . -.

.I I

!

! ;

f\.djuster

insured

plaimant

baimNo.

folicyNo. bateofLoss

Bud O'Brien . Hourly Rate ($$/hour)= 51.50 Hours to date 66.16

I I

--4/7/2007

Mileage (.42/Mile) 350

transcribed statement

Pictures @ 2.25/pictur-e; · :··~ 140

. Payment 3407.24

Mi1eage Cost 147.00

Phone. Cost · 22.80

Office Cost 4 71.96 Picture Cost Misc. Cost

315.00

j)J.19~0°1/

DEC 2 6 2ff13'

Gross Total $4,364.00 ~ate

4/9/2007

Time (mins)Action Taken

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I

4/9/2007

4/10/2001..-' . .. .

4/11/2007

4/17(1007

4/19/2007

4/19(1007

4/20(1007

4/20/2007

4/2612007

4/27/2007

5/1/2007

5/7/2007

5/8(2007

5/8(2007

5/8/2007

5/9/2007

5/9/2007

5/9/2007

1. 5/11/2007

5/13/2007

I· 5/14/2007

I 5/14/2007

5/15/2007

I 5/15/2007

5/16/2007

,, 15 set up & review new assignment.

IO phone call insured set apt

:225 travel to loss location, met· with the insured, obtained non waiver

0 agreement, discuss with her PA Alex Campbell, obtained statement inSllied

0 inspection. of damages

15 reviewed correspondence from PA

240 travel to loss site, met with PA reviewed scope o~ damages

O and photographed

20 obtain state JicllDSing record

240 review records in preparation of report to earner

20 review report to carrier ·

5 phone can from Alex Campbell

240 navel to loss site, met with the PA Alex Campbell

0 reviewed damages bldg, pp

20 phone conversation· wiih Trevor MilC!.and with Alex Campbell

15 set up conference call with the PA and Trevor :Miles

20 phone convCJ:88iion with PA and with Comp

360 reviewed file in. preparation of estimate

30 phone conversations with Trevor Miles and with Gene Ivanoff3

10 phone conversation wifu the PA

10 phone convenation. with Absolute Analytical to survey for smoke damages about the premises

180 reviewed file in prepan;tion of report to carrier

45 review report, photos, statement & enclosures to carrier

210 travel to the loss site metwfth varioUll contractors & vendors

0 Serv Pro, Laurens Const, Dave Byrd Absolute Lab, .Alex Campbell PA & the .insured

10 phone call from the PA gave me his email address and also noted he would file for

0 appraisal

75 ?"epared estimate of the gannent cleaning

10 phone conversation with Gene Ivanoff he stated that PA has tiled for Appraisal

10 correspondence from Laurens Constroction.

5 correspondence froµi. Absolute Analytical

200 reviewed estimate from Laurens Const & prepared correspondence to Laure;ns

' 0 on :recommended changes to 1heir estimate 00921) I!

5117/2007 60 reviewed file & assess 1he values ACY

I 5/17/2007 115 reviewed file in preparation of report to eanior LlEC 2 6 2013 511&/2007 60 reviewed filed in preparation of report to eamor

5118/2007 15 phone convernation Laurens Construction

I 5121/2007 10 phone conversation with Gene Ivanoff ok to proceed wi1h 1he bldg

0 & personal property figures. he did not want me to deduct the

I 0 front door or the pre existing damages to the 1/r, foyer and

0 front bedroom ceiling

5121/2007 S phone call to PA left message

I 5122/2007 5 phone call to PA left phone message

5/22/2007 10 prepared e mail message to PA on settlement offer

I 5/22/2007 5 phone message from the PA

5122/2007 15 pllone call from the insured reviewed the settlement figures with her

5/23/2007 120 'reviewed file in preparation of correspondence to PA wiih enclosures

I 0 and prepared correspondence to carrier

5/31/20Cl.7 15 phone call from Al"" Campbell reviewed a _JlUillber ofump_ire

I 0 candidates I refused all recommended by PA he referenced

·• O Ted Foster with Signal will clarify that he doesnot.b.ave any conflicts

6/1/2007 5 phone message left for Ted Foster

I 6/lfl.007 IO phone conversation with Trevar Miles Gene is out o)'the office

·o discuss appraisal issne by PA Trevor said that they would like me to

I 0 be the appraiser discuss issne of Ted Foster as Umpire advised Trevor

0 that we would want to make snre there would not be any conflicts

O indicated tha: 1 would discuss with Ted Foster first

I 6/lfl007 JO phone call to PAretumedhls call advised that I b.ad a phone message into Ted Foster

0 would not agree to his nmpire apt at ftrls time I will further advise after speaking with

I 0 Ted Foster as to no conflicts

6/4f2007 5 phone call to Ted Foster left phone message

6/4/2007 10 pbane conversation Ted Foster on umpire apt

I 6/5/2007 45 review file in prcparaticn ofreport to carrier

6/612007 10 phone conversation wi1h appraiser relative to the umpire apt

I 6/6/2007 20 correspondence to appmiser for the insured

6/6/2007 20 correspondence to umpire

6114/2007 180 travel, met at loss site with appraisal panel, reviewed scope of damages

I 611512007 15 correspondence to carrier with bill from Absolute Analytical

6121/2007 120 travel to Cleaners met with Mr. Knn

I 6/27{1007 10 phone conversation with Gene on 1he requested ALE documenil!

6127/2007 IO phone conversation with umpire advised that wowould have report to !rim by Tuesday of

0 next week

I 6/27/2007 3 0 obtllined fumlture appliance bid

6127/2007 90 reviewed file & prepared spreadsheet on building .items in dispute

I 6127/2007 IO phone convernation with Ted foster

6/27/2007 30 ABC OpPliance quote on the stove

6/30f2007 120 reviewed file finished spreadsheet on building items in dispute

I 7/2/2007 240 prepared appraisal report wit:h enclosures

7/5/2007

7/9/2007

7/9/2007

7112/2007

7fl4/2007

1fl4fl001

7/l4l2007

E 7 /26/2007° .

E

I I I I I I I I I I I I I I

10 reinnred phone call to Gene advised no award yet His question was

0 relating to fhe deductible

5 phone message from Umpire regarding apt

10 confirmed apt with Alex CampJ,ell fur Thursday 7 /12

180 !ravel met with appraisal panel reviewed damages

IO phone discussion with Gene Ivanoff advised that I did not receive the appraisal award

10 pbon.e call to Alex Campbell and Ted Foster regarding appraisal award

S fax appraisal award from umpire

75 reviewed file in preparation of report to earner

3970

''

)

-.- ........

00921.1 R 2 B 2Ui3

I I I I I I I I I I I I I I I I I 1 I

BILL TO

American Fellowship 26001 Telegraph Rd . Southfield, Michigan 48034 Attn Trevor Miles

, .. ,

I •

ITEM ·.. DESCRIPTION

Property Loss al ClaimN


Date of Loss 11/13/2005

miscellaneous copies, binders, postage

Thank you fur your business I

I • I •

,-""'.-..=-..11111."t

DEC 2 6 20fl3' 0092i'

DATE

11123/12

SHIP TO

Liberty Claim Services, LLC P.O.Box2064 _Brighton, Michigan 48114 Phone 810-227~0517 or 810-599-1771

'

DUE DATE

QTY

85.17

637

Subtotal

0%Tax

25

Total

I

12!2.3/12

RATE

51.50

0.42

2.25

Invoice INVOICE#

11529

P.O.NUMBER

AMOUNT

4,386.26

267.54 53.00

763.21 •.. 56.25

55.20 .

5,581.46

5,581.46

Bud O'Brien . .

Hourly Rate ($$/hour)= 51.50 DEC 2 £ ?Oil

Hourstoilate Adjuster

Jnsmed Claimant I

Claim No. ··- Mileage (.42/Mile) Payment ·

(_..-637 ) ) :Mile~e Cost ·~~ ..... N ••< ,• .":: '

Phone Cost

bate ofL~s · 11/13/2005 Pictures @ 2.25/picture

copies/binders/postage

Office Cost

25 . Picture Cost

I I I I I '-

I I I

I t; ' I f L··

I·

I

Misc. Cost_

Gross Total

Time(IlllD.S) Action Taken

6/20/2006

6/20/2006

6/21/2006

7/11/2006

7/11/200~.

7/25/200b- .-.

7/25/2006

7/25/2006

6/30/2006

8/1/2006

8/1/2006

8/2/2006

8/2/2006

8/2/2006

8/2/2006

8/2/2006

8/2/2006

8/3/2006

8/3/2006

8/3/2006

8/4/2006

8/5/2006

8/8/2006

8/8/2006

8/9/2006

8/10/2006

8/11/2006

8/11/2006

8/11/2006

30 obtain file from American Fellowship

105 organize and review file

c···i®?'ttavel to loss sito, inspection, reconciled damages ... __ ....... .......---10 phone conversation with Steve .Anderson EFI Global

--190 review file in preparation of report to Gene Ivanoff

10 phone conversation with Trevor :Miles i:Js to om opinion

0 on the cost to repair the building

60 review estimate .in preparation of spreadsheet

7 5 reviewed file in preparation of report to carrier

@ travel to loss site area to meet with Bob Tanis o~d statement

10 phone conversation with Gene Ivanoff ok to offer settlement on the PP as figured by

0 GAB ok to proceed with the engineer and the contractor on the bldg

5 phone call to R. Burgess LTM

5 phone call to R. Burgess LTM

5 phon call to R. Burgess L 1M in response to his return call

5 phone call. to Steve Anderson eng

10 phone call wifh EF1 & Steve .Anderson :insp for next week

0 will have to arrange access :frmn 1he atty

10 phone conversationR. Burgess

10 phone conversation with S. Shipper

10 phOne conversation. with Laurens Constmction they are willing to

0 work with -us on an agreed cost of repair they will charge $125 per hours

5 left. phone message for Stanley Builders

10 phone conversation with. R Burgess regarding PP

5 phone mes~e left for Stanley Buildm

10 phone call from Stanley Builders they are :wflling to work with us on an agreed cost of repair

10 phono conversation with Gene ok to use either contractors

5 phone message left for Lauren Colllltruction he is out of town until 8/14

10 discuss contents, storage & rental items with atty Burgess

1 Q phone conversation with Aladdin Cleaning re storage

~O phone cqnversation witlt carrier regarding. mold issues & code up grade coverage

10 phone conveisation Scott Chandler Testing Engineers apt to inspect loss.site

10 phone conversation with R. ~gess regarding PP

Page 1.

85.17

4~$6.2(i1 (i.§1 .. ~4 .. ·

53.00

-!

763.21 56.25

55.20

. I

I ' ,,

I t <" rt·

I:

r ·,

•

f. ·< ,,

J{i

I ;· ..

8/14/2006

8/14/2006

8/15/2006

8/15/2006

8/15/2006

8/16/2006

8/17/2006

&/21/2006

8/2112006

8/22/2006

&/22/2006

8/22/2006

8/22/2006::-

8/22/2006

8/221Z006

8/22/2006

8122/2006

8123/2006

8/23/2006

8128/2006

81'.2912006

8/29/2006

8129/2006

912/2006

9111/2006

9/12/Z006

9/12/2006

9/1312006

UtC 2 6 ZU1.i 10 phone conveniation with Stuart Shipper

100 travel inspection. of scene with .hygienist framing, LR Utility room,

10 phone conversation with Howard Laurens discuss inspection and apt fur 8123

0 will also have tta<!es associates available for inspection

10 phone conversation with Gene Ivanoff regarding cost assessment by TEC

135 review file in preparation of report to carrier

15 phone conversation with Rex.Burgess

75 review file in prepa,:ation of report to carrier

l O phone dis<;ussion with Trevor Miles

10 phone conversation with Rex. Burgess his cleints want $180.000 between bld / conll!

10 phone call with Trevar Miles will have discussion with

0 claw mgr Mr. Handy, & with Gene

10 ph,;me conversation with Trever, Mr. !Iandy, will go up to $140, 000 to settle

0 building. Will also discuss contents at $15,000 and ALE continues

. 10 phone call with Rex Burg""'! indicates bis client wants $160,000 plus contents and ALB

10 phone conversation with Trevor indicates Mr. Handy had to leave indicated Burge.ss

0 js at $180,000 advised that we had offered $15,000 on contents on a full release and

0 a compromise on the building between their $120 and the insured $160,000

0 OK with Trevor tu offer $160,000 total

10 phone conversation with Rex Burgess indicated that !lie co has offered $160,000

0 total bldg and contents he will not recommend but will talre to bis client ad,nsed

0 that we are still in appraisal and l believefuatthe·property can be prepared for less

0 will be putting our estimate together beginning on 8/23 if matter is not eon.eluded

10 call from Rex Burgess he advised that his client will settle for $170,000 indicated that

0 we would speak with the co and we thQught that his clients were not realistic

10 phone conversation with Trevor Miles they will hold at the $160,000 total between the

0 blg & fue contents

10 phone c<mversation with Rex Burgess advised thai we would proceed with the

O appraisal process .. AF is holding at $160,000 for bldg and contents and I .

0 am of the opinion 1hat the fire damages can be repaired far less than their

0 $150,000 demand on tho bldg he will advise if his client changes

l O confirmed inspection with Laurens Constru.ction and the 3 trades entities

480 trave_l, .inspection, with Howard Laurens, pumbling, heating and electrical

10 phone conversation with Dave Beger

IO phone conversation with Rex Burgess regarding the personal prop<;rty and tlie

0 storage he indicated that their client is looking over the contents list

20 phone calls on suggested umpire appointments

30 prepared correspondence to Stewart Shipper on Umpire apt

360 prerpared building estimate

30 correspoi;idence umpire & Gene Ivanoff

1 O phone conversation with Howard Laurens to review estimate

60 review file in preparation of meeting with Umpire on 9/13

300 travel to meeting site met with Umpire and 8. Shipper, reviewed issues

0 taveled to loss site reviewed bldg damages with Umpire and Appraiser Page2

.,

9/14/2006

9/15/2006

9f29/2006

9/3012006

10/1/2006

10(2/2006

10/3/2006

10/5/2006

10/6/2006

10/23t2006

10/24/2006

10/25i2006

l112i2006

11/8/2006

11/9/2006

I 111912006

11/14/2006

I lll2412006

11,128/2006 -· I

l 1l29/2006

1211/2006.

N" ;.,: ,.

t 12/112006

.. ,,, ~.

,:,. i[·!

12(2/2006 ;,a

12n12006

· 1217/2006

12/8/2006

1/22/2007

2/1912007

2,/20/2007

0 for the insured called carriers-poke with Gene lvanoffie developments

75 review file in preparation of report to Gene Ivanoff DEC 2 ~ Zil!l

50 reviewed file fn preparation of correspondence to the umpire & appraiser

30 prepared Ieplacement valuation Xactimate

330 review file, in preparation of our report to umpire

480 review file in preparation of our report to umpire

120 review report to umpire and orgaoize enclosures

10 phone call from Umpire John Zeldam he wanted m acknowled,!;e receipt of our materials

0 and confu)nation that we sent our materials to appraiser Shipper

15 prepared fux document to Appraiser for insured

105 reviewed file in preparation ofreportto carrier

90 review :file, prepared notes in preparation of meeting with Umpire & insured's

0 appraiser

285 travel to office of Umpire, appraisal panel reviewed replacement cost

, 0 pre loss, ACV pre loss, various sq footage of building, repair estimates

0 Tax assessments,

60 reviewed correspondence from appraiser award format prepared

0 eoirespondence and enclosures witb cc to Umpire

90 prepared report to Gene Ivanoff on tb.e awru:d by the umpire and

0 the lllS~dts appraiser

10 phone call from Gene regarding the conteots advised we would call Burgess on 11/9

15 review file I pbone call to tb.e atty Bmgess regarding 1he contents

OLTM

l O phone conversation with Trevor Miles regarding engineer & contractor lnspection

l O phone conversation with Atty Burgess office he is out son killed in Iraq

OLTM


5 phon.e call to Rex Burgess left phone message .

io phone conversation with Rex Burgess made phone apt to review coots

10 checked model numbers on the range and dishwasher for replacement cost with ER8

0 not good IlUillbers

15 phone conversation with Rex Burgess indicated

0 model numbers were not good reviewed building items that are on 1he contents

0 inventory he will review with.his client indicated that we wonld fax over the pages

0 involving fue building hems ll!ld we would speak again on Monday 12/4

30 reviewed file m preparation of letter to RBurgess

10 phone con.vorsation. with Rex Burgess advised tllatthe Blinds are considered part of the

O building not contents still obtalning RV on 1he range and the dishwasher

5 phone call to ERs left phone message

10 phone conversation with ERS replacement value on the dishwasher 424 The range double

0 oven is not mad6 any more figure $700/800 replacement value

20 review file in preparation ofletter to atty Burgess.

10 phone conversation with the imrured's atty

10 phhone conversation with Gene Ivanoff Page3

-•,-1 <

1, I

I 2/20/2007

I 3/112007

3/2/2007

I 3/16/2007

3/16/2007

I 3/26/2,007

3/30/2007

413/2007

I 413/2007

I 4/3/2007

I 41312007

I 4/3/2007

I 4/3/2007

4/3/2007

4/10/2007

I 4123/2007

h

i r

' ,:·

I l lI

10 phone conversation with the insured

75 review file in preparation of correspondence to the insm:ed

0 atty and to Gene Ivanoff

10 ph<me conversation with Gene OK to send letter to the insm:ed's aity

10 review correspondence frorn atty Burgess

10 phone call to atty Burges., b.e was in meeting with client left phone message

10 phone call to atty Burgess office he is on vacation this week

20 reviewed file in preparation ofletter to atty Burgess

10 phone call to the insured's attorney left phone message

15 reviewed contents issue with the insured's atty advised

0 ACV figures, reinstatement figure and RCV figure including the bllnds

0 Burgess said that his client would settle for S 17,000 on a full release

10 revlewed :figures wtih Trevor Miles he ok settl,,,;,ent on a full release as to the ' ' O personal property fur$! 6,000

10 phone conversation with Rex Burgess discuss full settlement on the PP for

0 $16,000 discuss the depreciation amnunt Jhis would be a better Ihm 50% split

0 the insured's atty agreed to recommend to his client

10 exchange of phone calls wifu clamumt attyinsored will acceptfue $16,000

10 phone call Trevor Miles indicated 1hat1he insured will accept $16,000 on the PP

· 60 prepared report to carrier and settlement release

15 prepared fax to atty Burgess

30 prepared closing report to carrier

5110

Page4

• I ' '·

00921}

/

;. I

:· i. i {-.

l: r: f,

t. t ' ),

f (.

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I ,

,,,-..,.~-- -. .) 11

DEC 2 6 2013 ,r· ,.,9··2·~ . ._, '--" .

Invoice .D~TE.

12/31/12 11554

.. : .· ::"··.- -s1y:-t.cr .. _:::-,'' ' .. .. ·. :.··: ... SRIP TO,:_ .. , . ·- . ·. '

. . ' : . ::. .. · .. '-· ·. .. :" ... .. .. · . - ., . ._ . .·

American Fellowi.bip Liberty Claim Services, LLC 26001 Telegraph Rd P.O.Box2064 Southfield, Michigan 48034 Brighton, Michigan 48114 Attn Trevor Miles Phone No: 810-227-0517 or 810-599-1771

I'

· ... ·.j;.0,.-Nl:J.MBEfi°-:.'·. · .. • ·. . . ·- . ·-· ..

1/30/13 . , . .. ... -

:._-.;· .. ~--'~~~-- · . .-.- . ·. ·.' · · . ::.··. · · _·:·<:.oi::sca1i;i:r.10N.· . . .· . __ ... ·-.. : .... . _·_ .. · ... _._· . .-ot.v ·· ·,.RA ... , _._TE :. :::·_. . _.· ·_:: .. .. _.A.~?_q_· ~.r,_ : · .. · . ... -- .:. -.~ ..... _. ~- •• :-:- ·--: • •• : .. \.I .. - "./' ••• H ••

Property Loss

phone office

Claim No: Policy No: Date of Loss: 2/2/2006


1.67 51.50 86.01

Subtotal

0%Tax

>rrit:if.-... . ·: .. .. -· ...

J

2.QO 15.00

103.01

-;.-. ··.· .. :.·- .. ,-; : . '.:· :

. .··.· ·'· ._.-,-·: ._;'-·_··,·,.::).~~-Qf-. ..... . . ,.:·- ... . .. . ...... .

I

I I l. i'·

I

llEC 2 6 lDJJ;

Adjuster Bud O'Brien Hourly Rate ($$/hour)= 51.50 IIoms to date = 1.67 Insured --- Payment = 86,01 Claimant Mileage (.4~) 0 Mileage Cost Claim.No. - Phone Cost 2.00 Policy No. Office Cost 15.00 Date ofLoss 212/2006 Pictures @ 2.25/picturo 0 Picture Cost

Misc. Cost 0.00

f'

Gross Total $103.01

Date -:-- Time (mills) Action Taken

· 2/8/2008 _-. 10 phone conversation with Trevor Miles 1he insured wants to contilllle wi1h the appraisal------------- - -- -- --- ----- -- --

'

t

2/14/2008

3/14/2008

~/14/2008

4/27/2008

7/14/2008

3 0 :reviewed file in preparation of letter to the :insured

10 Trevor Miles had asked that we would send an additional letter to the insured

0 as we have not he~d from her appraiser

20 reviewed file in preparation of lotter to the insured

10 phone conversation with Trevor Miles

20 reviewed file in preparation of letter to the :insured

100

ri:'

,. \"

I •

.. ... .. BILLTO ·· · .. . :_:· .. :\'. ' .. . . . .. .

American Fellowship 25925 Telegraph Rd Suite200 Southfield, Michigan 48033 Attn Trevor Miles

, .

. Thank you for your business!

. ... ] . ~-

.- .. . . . . .... ''

-

··-- ';.$$24LQ,.

1' I

•.DATE;: .. · ': ....

12/31/12

' .. - .. r:, . ,' · .SHIP._TO- ( · ...

Liberty Claim Services, LLC P.O.Box 2064 Brighton, Michigan 48114 Phone No: 810-599-1771

.. ., '

·--··· .. ,-

DEC 2 6 2013

Invoice

11560

.- b.ut.DATE. ·.. .P.O. NUMB.ER_.,.._;- · · -~-~------'-+'-----'---'. ~··_,..,_; - : . . -:. · .. . .......

Subtotal

0%Tax

61.46

.. -: . ·. .~ .. · .: - :;:·:-'-~_1 . .46"·

.• . .. :. ..

:·Adjuster I

Insured ' . : Cl8lIIlant

Claim No.

PolicyNo.

r DareofWss

I I I: Date

I 10/17/2006

11/10/2006

Bud O'Brien Hourly Rate ($$/hour)= 51.50

M'tleage (.42/Mile)

-10/11/2006 Pictur.es @ 2.25/picture 0

Time (min~)Action Tak.en 15 set up & reviewnew assignment.

. : 45 reviewed file in preparation of letter to the insured

Hours to date 1.00 Payment 51.50 Mileage Cost 0.00 Phone Cost 1.00 Office Cost 8.96 Picture Cost 0.00 Misc. Cost 0.00

Gross Total $61.46

.................... · ..... ~ .: . .. · ........................... 60 ................................ ·-···-····-..................................................................................................................... , ......................................... u1::c ... 2 .... s .2011 ... ................................. . I .. .

I I ··-

' 1· :·'.ii.

i I ~(

I ~;·.

I I I l !: .. '•

00921::

,;, .

' '

BILL TO

American Fellowship 25925 Telegraph Rd Suite 200 Southfield, Michigan 48033 Attn Trevor Miles

, '

ITEM DESCRIPTION

Collection Fees Filing Fees milage ' phone/postage labor

0092:1! DEC' .2 6 2013

Invoice DATE INVOICE.#

12/5113 11591

. SHIP TO

Liberty Claim Services, LLC P.O.Box 2064 Brighton, Michigan 48114 Phone No: 81()..599-1771

1 PUE DATE

I

P.O. NUMBER

1 ..........J/4114 ····· ··•·· . .... .. .. ········.

QTY RATE ,AMOUNT

120

9

Subtotal

D%Tax

Total·

0.42

60,00

190.00 50.40

7.56 540.00

787.96

787,96

i I

·1 I

AMERICAN.FELLOWSlllP MUTUAL PROOF OF CLAIM FORlV.l)t r. ?., {j ?I\\'\· Deadline for filing: - 00922

Please read ca1•efully before completing this form. Each section must be fully completed, Instructions a1·e attached. If additional copies are needed, please photocopy or download the Form at: www.michigan.gov/difs then click "Who We Regulate", then American Fellowship, then "Prnof of Claim Fol'm". File a scpal'atc ''Pl'oof of Claim,, form for each unrelated claim.

FOR OFFICE USE ONLY Date Postmarked: Part 1: CLAIMANT INFORMATION Name:

Address· l; Lester Bud o' Brien *** Address2: P.O.Box 2064 Continue City:arighton, State: Michig Zip Code:4a114 Country:

Proof of Claim Number: Date Received:

Does an attorney represent you? Yes ( ) No ( x ) If yes, provide attorney's name, address & telephone number:

Part 2: INSURED/ POLICY INFORMATION Natne of Insured:

Agent Name or Number: Part3: CLAIMINFORMATION

imant/Patient: hnNumber;

Amount of Claim: ·Ba, _ --,.,..---+--D..;.at--'-e--'-C'-':l:":'aim~B-=e=--c=a=-'-m'-:::e~D-'=u--=e::i: :i-ei~:l:ft1EH:'YT€lti,a-±1 heck tl1e statement elow that 'Gesi. desciibes SECURED CL our claim:

POLICYHOLDER OR THIRD PAR.TY CLAIM Claim by insured for POUCY BENEFITS or claim against an insured for POLICY BENEFITS.

RETURN OF UNEARNED PREMIUM OR OTHER PREMIUM REFUNDS Portion of paid premium not earned due to early cancellation of policy or audit ad'ustment.

POLICYHOLDER COLLATERAL

CREDITOR Agents, Attorney fees, Vendors, Landlords, Lessors. Consultants, Cedants and Reinsmers

ALL OTHER Describe:

Describe the basis and nature of the claim and attach all documents supporting the claim. Attach additional page, if necessary. Lib t Cl . 8 · LLC id d Cl · · er y aim ervicesr prov e ai

• .. It • 1,

bill

***

Has a lawsuit or other legal action been instituted by anyone regarding this claim? Yes ( X ) No ( ) Ify~s,providethefollowing: Continue c e No· 13-27261 K Court Where Filed: Livingston Cti circuit Date fl(~~ Case Number: 1 / 13 / 2013 Plainti s : Liberty Claim Serv ces, LLC ***Defendan s : sh. Have you reoowed:..any w-:tm®tmru..tnclaim which is the st1bject of this Proof of Claim from i P an source? If the total amount received:$ and iderlli all sources: No

CONTINUED ON REVERSE SIDE Do you owe any money 1n the Company? If yes, specify the amount:·$ And the reason:

No

Is this a secured claim? If yes, specify all security for such claim:

No

Is this claim contingent or unliquidated? If yes, specify the reason:

No Part 4: AFFIRMATION

PROOF OF CLAIM AMERICAN FELLOWSHIP MUTUAL INSURANCE COMP ANY

In Liquidation (the "Company") Ingham County CircuitComt, State of Michigan; Case No. 12-1173-CR

The undersigned subscribes and affirms as true under the penalties of pe1jury as follows: that he or she has read the foregoing Proof of Claim and knows the contents thereof; that this claim in total amount of$ 3 7 3 5 2 ,•l b,gainst the Company is justly owing to the Claimant; that the matters set forth and In any accompanying statements and suppo1iing doci1ments are trne and correct; that no payment of or on account of the aforesaid claim has been received except as above stated; and that there are no setotfs or counterclaims.thereto except as above stated.

(/ . , & ~ v ~ ~,.,,' ,)t.1"-t-ui • L. tC:

Title or Official Capacity (if any)

Claimants Attorney (if applicable)

IMPORTANT NOTICES A. Proof of Claim must be properly signed and dated. Remember 1n attach all documentation. B. Deadline for filing Proof of Claims is December 12, 2013. C. If you have a change of address, you are required to inform the Liquidator at the address below of the new address in order to receive any payment that might be due. D. Return your completed fo1m to:

American Fellowship Mutual Suite 200 25925 Telegraph Road Southfield, MI 48033

E-Mail: [email protected] Fax: (248)-352-4921 Phone: l-(800)-648-6329

00922. \JFC ¼ G 7.0\1

AMERICAN FELLOWSHIP MUTUAL INSURANCE COMPANY PROOF OF CLAIM FORM


Page 1 Part 1 Claimant Information (Person Making Claim):

Address 2:

Page 1 Part 3 Claim Information:

Question: Check the statement below that best describes your claim:

CREDITOR: LCS/Lester Bud O'Brien was a Prefen-ed Creditor employed by American Fellowship to provide claim services including recommendations specific and relative to the claim, contract/policy, applicable laws and damages.

Question: Describe the basis and nature of the claim ...... .

Whereas, American Fellowship was aware that Libe1ty Claim Services/ Lester Bud O'Brien was an experience insurance Professional and believed that it was beneficial to have available to it, LCS / Lester Bud O'Brien extensive knowledge and experience concerning the adjustment of Property and Casualty Claims and as American Fellowship's appointed Appraiser relative to damage disputes with claimants, its policyholders, according to the Appraisal provision of the Policy.

Whereas, American Fellowship Mutual desired to engage in a continuous claim consulting relationship with LCS/Lester Bud O'Brien for specific operations of its business and requested that LCS be available to AFM, for investigat_ion activities, damage assessments including appraisal appointments, advice, claim negotiations, settlements, and expertise.

Page3

\ILL:), \I J1l\3

AMERICAN FELLOWSIDP MUTUAL INSURANCE COMPANY PROOF OF CLAIM FORM


Whereas, American Fellowship Mutual agreed to pay LCS/Lester Bud O'Brien and hourly service fee and the reimbursements of expenses, upon receipt from LCS / Lester Bud O'Brien supporting documentation inclucling all those reasonable, appropriate and necessary business expenses associated and incurred as a direct relationship and resulting from the performance ofLCS/Lester Bud O'Brien's claim services to and for American Fellowship Mutual.

Whereas, there has been continuous representation provided to American Fellowship and its policyholders by LCS/Lester Bud O'Brien for approximately 10 years through February 2009.

Question: Has a lawsuit or other legal action been instituted by anyone regarding this claim? The lawsuit was clismissed without prejudice on June 25, 2013.

LCS / Lester Bud O'Brien expressly reserve the right to amend and supplement the Proof of Claim.

Page4

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 34 35 36 37 38 39 40 41 42 43 44 45 46 47 48 49 50

Name

51 Collection Fees

amount Appointed American Fellowship Claim Consultant \)(C 7, (j 1\1\t\

$886.27 $2,975.35 $2,303.34 $3,191.33 $1,377,81

$843.56 $1,097.49 $1,304.66 $1,011.36

$629,01 $372.90 $905.22 $634.28 $909.44 $776.35 $525.11 $468.43 $461.45 $495,79 $329.15 $336.67 $465,23 $404.85 $771.96 $801.57 $457.16 $541.62 $521.27 $448.75

$77.58 $473.49 $376,12 $270.02 $616.28 $597.59 $722.41 $493.19 $481.53 $487.28 $392.96 $815.68 $706,04 $602.10 $456.16 $419.49 $289.20 $319.23 $783,64 $302.91

$1,028.72 50% $393.98

.... I -..,..$__:..;....;...;..;..;;..;;.._,I _ 37,352.98

1

DATE

11/23/12

DEC 2 G ?.013 Invoice INVOICE# .

11530

------------------·····----·--········---. ·-------------------Bill TO SHIP TO 1----------------·--·-..---........... _, .. ~ ... ~.----~--.-· ~-- .. ~-.... --------------

American Fellowshlp 26001 Telegraph Rd Southfield, Michigan 48034 Attn Trevor Miles

liberty Claim Services, lLC P.O.Box 2064 Brighton, Michigan 48114 Phone 810-227-0517 or 810-599-1771

....._ _________________ ..,___ _____ ... ··---· ·-··· ........ _, ___ ··-·--··· ···-· ··--····-------'

DU~ DATE P.O. NUMBER

12123/12

ITEM DESCRIPTION QTY RATE AMOUNT -·

Property loss 12.17 51.50 626.76 Policy No: Date of loss: 4/17 2007

mileage 60 0.42 25.20 phone 10.50 office 109.06 photographs 51 2,25 114.75

..

..

...... -- ..... ,_ • .,,,, •• ,..,,.,..._ •• ,, .. ,,.-•,u•,•-.•••.,••,•••--·-· •• ·-------···· ... Thank you for your business! Subtotal 886.27

0%Tax ·--···--··-----·-----

Total 886.27

.... _......., ____ , .. , .... -... -.................... _ ........ ___ .. __

Adjuster Dud O'Brien Insured Claimant Clalm.No.

Policy No. -Date of Loss 4/17/2007

Date Time (m.ins)

4/17/2007

4/17/2007

4/18/1987

Hourly Rate ($$/hour)=

"Mileage (.42/Mile)

Pictures @ 2.25/picture

Action Taken

15 set up & review new assignment.

10 phone call to the insured & tenant

10 phone call insured contact apt for 4/19

51.50

60

51

Hours to date Payment ·Mileage Cosf"',,.., -

Phone Cost

Office Cost Picture Cost

Misc. Cost

Gross Total

12.17

4/19/2007 225 travel to loss s.ite, met with insured's contact, tenant & with Sun Glo 00922

4/20/2007

4/23/2007

4/24/2007

4/24/2007

4/25/2007

4/26/2007

4/27/2007

4/27/2007

4/28/2007

4/28/2007

5/7/2007

5/7/2007

5n/2007

5/10/2007

5/14/2007

5/25/2007

0 photo & scope damages

10 phone conversation with Gene Ivanoff will hnve a CO performed

10 correspondence from Sun Glo

10 phone call from the insured on status indicating the co was having the

0 cause of the fire determined

10 phone call to Hem don as Gene was out Jeff Terski indicated that

· 0 he made an inspection

100 review file in preparation of estimate

10 phoi1e call to the insured advis-ed we would review with carriel' and advise

75 reviewed file in preparation of report to carrier

10 pllone conversation wlth Gene Ivanoffwill .review our materials and then advJse

75 review fi1e in preparation of report to carrier

30 review report & enclosures to carrier & label photos

10 phone conversation with Gene Ivanoff ok the estimate on this cl11im

0 he also will consider the temp at the suggested $362

15 phone call to the insured L TM the insured called back gave llim our repair

0 figures insured asked that we would fax over the estimate

10 prepared note fur :fux infonnation to the insured

10 phone conversation with the insured. he indicated that he would arrange for the repairs

0 within our repair estimate of $4807 .31

40 prepared letter to the insured and ProofofLoss document

45 review file in preparation of closing report

626,76 25,20

10,50

109.06 114.75

0.00

$886.27

730

\)\ c ·?, 11 zon 00922

00922 l

F,t~,--·+-__ -___ I_N_~-~5-':-:-#--~

BILL TO SHIP TO 1-------------------- ~-----------~----··----···----·-


ITEM

Property Loss Insured: Polley No:

DESCRIPTION

Date of Loss :2/11 & 6/24/2007 mileage phone office photographs

Liberty Claim Se,vices, LLC P .O.Box 2064 Brghton, Mlchlgan 48114 Phone No: 810-227-0517 or 810-599-1771

DUE DATE --···--T··-·-·---

12/23/12

QTY RATE --·-···-... -. ........ -·~·

43.58 51.50

180 0.42

91 2.25

P.O. NUMBER

AMOUNT

2,244.37

75.60 23.60

427.03 204.75

____ ...1...._ ___________ •• , .... - •• - ........... ·-·--I----..L__----...L...-----------..l

Thank you for your business! Subtotal

0% Tax

Total

2,975.35

2,975.35

.... -................. --······--------------------·--·· ··-·····-·------------- -··-··. -- .

., · iDEC 2 G zon

Hours to date 43.58 Adjuster Bud O'Brien Hourly Rate ($$/hour)= 51.50 Insured - Payment Claimant Mileage (.42/Mile) 180 Mileage Cost Claim No. Phone Cost Policy No. - Office Cost Date ofLoss2/1 I & 6/24/2007 Pictures @ 2.25/picture 91 Picture Cost

Misc. Cost

Gross Total Date Time (mins) Action Taken

2/12/2007 15 set up & review new assignment.

2/l2/2007 10 phone conversation insured apt to meet at the loss site

2/12/2007 240 travel to loss location, inspection, photos, non waiver agreement

0 statement from the named insured

2/12/2007 0 phone conversation with Gene Ivanoff

0 regarding inspection and information from the insured

2/12/2007 120 reviewed file in preparation ofreport to carrier

2/13/2007 20 phone conversation with Gene &joint conversation with Tl'evor

2/15/2007

3/2/2007

3/5/2007

3/6/2007

3/7/2007

3/12/2007

0 & Mr. Netzy, We understood that AF will contact Herdon for a CO and

0 a title search

10 fax documents from the insured

10 phone conversation with Gene did want us to obtain statement from

0 nmrphy

5 phone call to phone number for Jerry Murphy

0 left phone message

5 phone call to phone number for Jerry Murphy


5 phonl? call to phone number for Jerry Murphy


10 fax document insured

2244.37 75.60 23.60

427.03

204.75 0.00

00922

$2,975.35

3/16/2007

3/19/2007

414/2007

4/18/2007

515/2007

516/2007

516/2007

5n12001

5n12001

5/8/2007

51912007

5/10/2007

5/11/2007

5117/2007

5/18/2007

5/2212007

5/23/2007

5/23/2007

5/24/2007

5/24/2007

5/29/2007

611/2007

6/l/2007

180 met with Jerry Murphy only way to meet with Murphy was to take him back to the l)\:C ')', f.1i im'3 0 Woodhaven area

2IO travel to loss location, met with PA, scope of damages

10 phone conversation with Paul Mabreck regarding market value assessment

lO phone conversation from the PA

560 reviewed file in preparation of estimate

30 label photos

30 prepare Replacement cost Xactimate


15 review report & enclosures to carrier

15 phone conversation with Gene Ivanoff ok to offer $41,811.56 ACV

0 & debri removal of$6000 to insured's atty Scott Smith

5 phone message left for atty Smith

5 phone message left for attorney Smith

15 disctlssion with Atty Smith regarding ACV & debri settlement offers

0 he will convey to his client and get back to me on 5/14 or 5115

10 phone conversation wtU1 Gene Ivanoff he indicated mat he had received a

0 cal! from the PA advised that we had not heard back from atty smith he sald that he

O would review wW1 his client and call me on 5/14

10 phone calls to Scott Smith left two messages

10 phone discussion with Gene Ivanoff advised we have not heard from Scott smith will

0 send letter

JO phoru, conversation with Gene Ivanoff wants me to call the PA Kramer

10 phone conversation with Kramer indicated that we would send P/L for the ACV

0 will send a copy to !he atty

10 phone call to Sco!I Smith he is not in obtalned fax number

105 prepared Proof of Loss, correspondence to the atty, with cpy to Pa

0 and prepared correspondence to carrier

10 phone call from PA wants the company to pay for replacement at another location

0 advised it needs to be repaired on site only

0 he claims 1hat he has statute information lo the contrary he will !l!x

15 reviewed fax information from PA and the DF 2 fonu

15 phone conversation with the PA said that the numbers are alright however

0 he wanis his client to be able to replace U!e building wlth another location

00922

6/lf2007

6/4(2007

6/4f2007

6/4(2007

6/l lf2007

6/12/2007

7f25f2007

7f25f2007

7(25/2007

7f25f2007

7(26(2007

7/27/2007

7/30(2007

8/Jf2007

8f2/2007

8/2(2007

8f2f2007

8/2(2007

8/6(2007

8/16(2007

8f29f2007

9/4(2007

0 will tl1e company agree I indicated no but that I would make a request for

0 a certified copy of the policy

5 phone call to Gene left phone message

60 reviewed file in preparation of report to Gene Ivanoff

5 phone call to Gene left phone message

15 phone conversation with Gene Ivanoff & clahn manager regarding

0 the replacement cost coverage asked Gene to send a certified copy of the policy

10 pllone conversation with Dana Kramer PA insured regarding the replacement cost coverage

20 correspondence to the PA with Certified copy of the policy

10 phone call from Czonak said that the other portion of his property burned

0 advised that he should contact carrier said that he did already

10 phone conversation witl1 Gene Ivanoff co would like us to inspect property

10 reviewed loss with claim manager, Gene and American Fellowship's atty

0 We should take statement, non waiver agreement and scope damages.

0 relative to another fire at the loss location on 6f24f2007

10 phone conversation with the insured apt for 7f27

10 phone call from the insured

240 travel to loss site, obtained non waiver agreement, travel to the insured1s work place

0 obtained recorded statement

15 phone discussion with Gene Ivanoff, claim mgl' and AF legal counsel

10 fax document from atty Klemanski

45 review scope & revised repair cost estim!lte

30 revfow scope & revised reconstruction costs

15 review photos provide copies to carrier

20 prepare memo to carrier with photos


10 fax document from atty Klemanski

10 Gene indicated that company is working with tho insurod's atty

45 reviewed file in preparation of correspondence to Gene Ivanoff

2615

-· -- ,.,.. =-~

00922 Invoice lDEC 2 G 20!~

-----------------------···--·······-··········-···-·- ----------, BILL TO SHIP TO

------------------1.--------···-·······--'------------1 American Fellowship 26001 Telegraph Rd Southfield, Michigan 48034 Attn Trevor Miles

L------------·········--···-············ ···--·-·-

.................. ITEM DESCRIPTION

..... Property Loss

Polley No Date of Loss: 2/24/2007

mileage phone office

--.wn-,-,.-.,.•-·----•~- •"


......... ·-··--------

Liberty Claim Services, LLC P.O.Box 2064 Brighton, Michigan 48114 Phone No: 810-227-0517 or 810-599-1771

--------------············-···-

..... n ............ -RO-DUE DATE P.O. NUMBER

• _,._H_,_.

12123/12 .-.,•.,. .

QTY RATE AMOUNT -,--.--.. -----

37.17 51.50 1,914.26

100 0.42 42.00 14.00

333.08

·--- ............ . ·- -·-·· ....... Subtotal 2,303.34

0%Tax ---··-····

Total 2,303.34

-----......

Adjuster

Insured

Claimant

Claim No.

Policy No.

DateofLoss

Date 2fl6f2001

2fl6f2007

2f27f}.007

2/}.8/}.007

3/1212007

3/16/}.007

3/}.7/}.007

3(}.8/}.007

3(}.8/}.007

3/30(}.007

3/30(}.007

3/31(}.007

4(}./}.007

4f2f2007

4/4/}.007

4/5/2007

4/6/2007

00822 n ,.., --·- - -·

[- l. ,., 1l .. ;i

Bud O'Brien Hourly Rate ($$/hour)"" 51.50 g .... ._ 8 f) ·70·\'J

ours to date 37.17 Payment 1914.26

Mileage (.42/Mile) 100 Mileage Cost 42.00 Phone Cost 14.00 - Office Cost 333.08

2/24/2007 Pictures @ 2,25/picture 0 Picture Cost 0.00 Misc. Cost 0.00

Gross Total $2,303.34 · Time (mins) Action Taken


10 pho.ne conversation with the insured, made apt to inspect loss on 2127/07

360 travel to loss site, met with the named insured & her husband, obtained Non Waiver agreement,

0 inspected loss site, obtained R/Stotement insured, surveyed property

0 phone conversation with Gene Ivanoff regarding developments, phone conversation, Herndon Investigations

0 phone conversation with.Emily AB Solutions, discuss advance payment of $2000

240 travel to loss location, met with the insured & Herndon investig~tion, scope damages


10 correspondence from Ja.rvjs Construction


20 review report to carrier

10 discussion with Gene ok to obtain a market value appraisal

10 phone convel'l!ation with the insured to gain access to home

15 phone conversation with American Realty Appraisal

285 review file m preparation of estimate

10 phone call to Mabrech Rea.lty Paul will do MV for $160

10 phone conversation with Gene Ivanoff to perfoIDl. the MV with Mabrech

10 coordinate inspection of property with Realtor Appraiser

10 coordinate debrl removal bid from Capital Wrecking

210 travel to loss location met with the insured & with Realtor regarding

4nnoo1 417/2007

4/19/2007

4/21n007

5/21/2007

5/2ln007

5/22/2007

5/22/2007

5/22/2007

5/22/2007

5/22/2007

5/22/2007

9/20/2007

11/2/2007

0 market value


30 prepared replacement cost valuation

10 phone conversation with Mrs. Nelson


00922

ID phone call from 1lll'Vis regarding temp bill will speak with AF

10 phone call to Geru, Ivanoff he will cheek and see if co will pay temp bill

10 phone call from Jll!'Vls advised cheeking

l O phone call to Gene Ivanoff he said co will pay temp ok to send in bill

10 phone call to Jarvis advised that the co will pay temps

5 phone message from Trevor Miles co will not pay temps at tWs time still

0 reviewing

10 phone call to Jarvis advised that co will not pay temps at this time still want to

0 complete their investigation and review oftWs loss

10 phone conversation Trevor Miles they are still reviewing claim no temps being

0 paid attWstlrne

10 phone conversation with Gene Ivanoffregardingreconcilng the Personal Property loss values

30 review file in preparation of report to Americ!lll Fellowship Ins

2230

BILL TO

American FeHowshlp 26001 Telegraph Rd Southfield, Michigan 48034 Attn Trevor Miles

ITEM DESCRIPTION

Property Loss ---Date of Loss: 3/21/2007 mileage phone office photographs

Thank you for your business I

DATE

11/23/12

SHIP TO

Liberty Claim Services, LLC P.O,Box 2064 Brighton, Michigan 48114

-, , i°' ;1 (,;\:~GD2 _i;:J.,·iJ W'UJ7~

· ·Invoice INVOICE#

11536

Phone No: 810-227-0517 or 810-599-1771

DUE DATE P.O. NUMBER

12123/12

Q1Y RATE AMOUNT

44.42 51.50 2,287.63

220 0.42 92.40 19.50

398.05 175 2.25 393.75

Subtotal 3,191.33

0%Tax

Total 3,191.33

Adjuster

Insured

Claimant

Claim No.

Policy No.

DateofLoss

Date 3/22/2007

3/22/2007

3/23/2007

3/24/2007

4/24/2007

4/30/2007

5/1/2007

5/1/2007

5/1/2007

5/2/2007

5/25/2007

5/26/2007

6/2/2007

6/5/2007

6/5/2007

6/5/2007

6/6/2007

6/6/2007

00922 Bud O'Brien Hourly Rate ($$/hour)= 51.50 Hours to ~ 2 6 aa\l2 - Payment 2287.63


3/21/2007 Pictures @ 2.25/picture 175 Picture Cost 393.75 Misc. Cost

0091.9 0.00

Gross Total Time (mimAction Taken


10 phone conversation with the insured apt for 3/23/09

27Q travel to the insured location, met with th.e insuredi obtained recorded interview

120 work on building estimate

235 travel to loss location, met with PA Norm Larkins, scope loss & damages

105 reviewed file in prepftf8tion of report

165 reviewed file in.preparation of report to carrier

10 phone conversation with Gene I van off regarding our report

10 phone conversation with Trevor Miles report should be completed today gave Trevor input on

0ALE

10 phone conversation with the insured's PA Norm Larkins

60 review file for preparation of estimate

300 review file for preparation of estimate

330 reviewed file, reconciled ACV contents and General Cleaning

30 totaled allowances on the personal property

180 reviewed file in preparation ofreport to carrier

30 reviewed report and enclosures to carrier

105 organized photos & label photos

20 phone conversation with Trevor Miles regarding dry cleaning

0 bills and ALE indicated that the insured has not demonstrated that

$3,191.33

6/6/2007

6/6/2007

6/6/2007

6/7/2007

6/7/2007

6/7/2007

6/11/2007

6/13/2007

6/14/2007

6/14/2007

6/21/2007

6f2.2/2007

6/22/2007

6/25/2007

6/25/2007

6/26/2007

6/26/2007

6/27/2007

0 thls was his principal residence

15 phone conversation withMr. Wilson, discuss documentation that

0 demonstrates that he had lived at the insured location

00922 D[C 1i 6 7.013

10 phone conversation with Trevor Miles reviwed discussion with

0 Mr. Wilson

r-.. .....,._ - -

150 travel to American Fellowship reviewed file with. everyone an ofter of $25,000 net was

0 made to the insured

10 phone conversation with the insured he is going to get another PA

10 phone conversation with Trevor Miles ad vised that we had heard from the insured

0 regarding the refusal of the settlement offer

10 phone call from the insured he asked about the clothes cleaning indicated that

0 I would be ch~c~g ist of next week

10 phone conversation with Paul Davis to inspect the property Ron will call back on

0 6/l2f2.007

105 travel to Larkings, also to Sinta

90 travel to dry cleaners Detroit, met with Chan Kim stated only picked up cleaning

0 twice Said Nonn Larkins had called him.

5 phone call to attyUpshawLTM

10 phone call atty said he would be representing the insured

10 phone conversation with the insured

10 phone conversation with Gene Ivanoff

5 phone call to the insured L TM

10 phone call to the atty, said he would be representing the insured

10 phone conversation ,vith Gene Ivano~updated activity

10 _phone discussion rergarding atty, he will decide on atty meeting for 6/27/2007

120 travel to meeting-place with insured picked up the discharge of the atty correspondence

0 also met with notary who witness & notarized the insured signature on the settlement agreement

6/28/2007 60 prep.ared correspondence to carrier with settlement agreement

2665

Insured -PolicyNo. -Date of Loss 3/21/2007

BILL TO


,·

ITEM DESCRIPTION -

Property Loss Policy No: Date of Loss: 6/ 6/2007



t:.JJ ... ,,,, uv;;J'°"",<,;,

OF.C 2 6 201~ Invoice

DATE INVOICE#

11/23/12 11537

SHIP TO

Liberty Claim Seivices, LLC P.O.Box 2064 Brighton, Michigan 48114 Phone No: 810-227-0517 or 810-599-1771


12(23(12

QTY RATE AMOUNT

18.84 51.50 970.26

60 0.42 25,20 14.B8

169.47 88 2.25 198.00

Subtotal 1,377.81

0%Tax ,

Total 1,377.81

Adjuster

Insured

Claimant

Claim.No.

PolicyNo.

Date of Loss

Date 6/18/2007

6/18/2007

6/19/2007

6/23/2007

6/23/).007

6/l6/l001

6/26/2007

6/l6/l001

6/28/2007

6/28/2007

6/).8/2007

7/5/2007

7/5/2007

7/7/2007

7/9/).007

7/9/2007

·c{jo!f22: Bud O'Brien Hourly Rate ($$/hour)= 51.50 Hoursrt'oC'di\te ?n 1318.84 - Payment 970.26


6/16/2007 Pictures @ 2.25/picture 88 Picture Cost 198.00 Misc. Cost 0.00

Gross Total Time (mins )Action Taken

$1,377.81


l 0 phone conversation apt to inspect loss on 6/19

240 travel insured location, met with the instll'ed, obtained a Non Waiver

0 R/St, scoped area ofbuilding d11mages & pp

l 00 worked contents restoration estimate and worked on bldg estimate

105 review file prepared report to the carrier

120 completed estimate on building & personal property


20 label photos

10 phone call :from Gene Ivanoff to go ahead with the settlement recommendations

5 phone call to the insured left phone message

10 phone conversation with the insured offered the insured $8705.79 on the bldg

0 $1247,73 on the personal property and $630 on the ALE claim for a total offer of

0 $10,583.52.

75 reviewed the inventory from the insured provided ACV, CIN and RC assessment

0·prepared report to carrier

10 returned phone call to the insured

10 returned phone call to the insured spoke to the insured son

5 phone call from the insured on 7/8 voice mail

10 phone discussion with Gene Ivanoff he has some questions on the fire report

7/9(2007

7/9(2007

7/9(2007

7/11(2007

7/1 lf2007

7/12/2007

7/16(2007

7/16(2007

7/17/2007

· 7(25/2007

7/30/2007

7/31/2007

8/2/2007

.......... "I 0 .\.v

0 he will fax over. He did indicate that the $414.08 on the contents would be a consideratic ....

o theywouldnotdoanyholdback DEC 2 G zon 15 phone conversati~n with-reviewed fire report she indicated that

0 she made phone report on 6/17 & the fire department came out on 6/21/07

15 phone conversation with the insured's contractor

10 phone conversation with Gene Ivanoff gave him the .information on the

0 fire' report made on June 21 and the fire official coming to the insured's

0 home on June 21 and also discuss the lapse in coverage fur non payment

10 phone conversation with Gene Ivanoff regarding preparing correspondence to the

0 insured with a Proof of Loss on the settlement offer

75 reviewed file, prepared lette to the insured, Proof of Loss

0 memo to· Gene Ivanoff on the request to release correspondence to the insured

10 phone conversation with Gene Ivanoff to send out the letter and Proof to the insured

10 phone cl\ll from the insured on developments the insured received our letter but has not

0 opened

10 phone call from the insured said that her contractor has sent us an estimate

75 reyiewed the insured's estimate in preparation of report to carrier

IO returned call to Saddie Quinn said that she was a PA and would be handling for insured

15 phone call from the insured said that she wanted the co to have the repairs made

00922

0 advised that we would not be replaeing all of tlie kitchen cabinets, nor would the· carpet be replaced

0 and the bath and 2 bedrooms would not be painted,

0 she said that she would written letter and return th{.l Proof of Loss

10 phone con.versatlon with the insured She indicated that Barrow Construction. will do the work based on my

0 estimate she ,va.nted co to include Barrow on ~e check as a payee

60 review file in preparation ofreport to carrier

1130

U\:.C 'J S 20\'J 00922 ,, .... -

Invoice DATE INVOICE#

11/23/12 11538

BILL TO SHIP TO

American FeUowsliip Liberty Claim Services, LLC 26001 Telegraph Rd P.O,Box 2064 Southfield, Michigan 48034 Brighton, Michigan 48114 Attn Trevor Miles Phone No: 810-227-0517 or 810-599-1771


12/23/12

ITEM DESCRIPTION Q"TY RATE AMOUNT

Property Loss ... Date of Loss : 9/13/2006

11.91 51.50 613.37

mileage 50 0.42 21.00 phone 4.50 office 107,19 photographs 10 2.26 22.50 Lightning Report 1 75.00

Thank you for your business! Subtotal 843.56

0¾Tax

Total 843.66

Adjuster Bud O'Brien Hourly Rate ($$/hour)= 51.50

Insured -Claimant Mileage (.42/Mile) 50

Claim.No,

Policy No. -DateofLoss 9/13/2006 Pictures @ 2.25/picture 10

lightning Report

Date Time (mins)ActionTaken 9/14/2006

9/14/2006

9/14/2006

9/18/2006

9/18/2006

9120/2006

9/26/2006

10/11/2006 .

10/18/2006

10/20/2006

10/21/2006

11/2/2006

1112/2006

11/4/2006

11/4/2006

11/17/2006

11/28/2006

11/29/2006

11/29/2006

15 set up & review ne~v assignment:

10 phone conversatioa. with the insured set up apt

180 travel loss locution, met with tha insured obta~ed non waiver & S/St

i 0 discussion with company regarding ordering lightning report

15 ordering lightning report Vaisala

135 review file in preporation ofreport to carrier

140 travel insured & with ERS inspection

15 phone conversation Gene Ivanoff will consider computer and have

0 other TC checked

60 reviewed file in preparation ofteporlto carrier

10 phone conversation insured

5 email insured

5 email correspondence from the insured

15 e mail correspondence to the insured

30 prepared letter & Proof of Loss to the insured

15 prepared correspondence to carrier


5 e mail from insured

10 phone conversation with Gene Ivwioffindicated insured's

0 inquiry on payment of claim. said about 1 week yet

10 advised the insured of the payment processing yet to rake place ·

715

nr.c 2 6 zmrr Hours to date 11.91 Payment 613.37 Mileage Cost 21.00 Phone Cost 4.50 Office Cost 107.19 Picture Cost 22.50 Misc. Cost 75.00

Gross Total $843.56

00922

DATE INVOICE#

11/23112 11539

,. BILL TO SHIP TO

American Fellowship Liberty Claim Services, LLC 26001 Telegraph Rd P .o .Box 2064 Southfield, Michigan 48034 Brighton, Michigan 48114 Attn Trevor MIies Phone No: 810-227..0517 or 810-599-1771

DUE DATE -P.O. NUMBER

12/23/12

ITEM DESCRIPTION QTY RATE AMOUNT

Property Loss -- ' 15.17 51.50 781.26

Date of Loss 2/4/2007 mileage 120 0.42 50.40 phone 16.80 office 136.53 photographs 50 2.25 112.50

Thank you for your business! Subtotal 1,097.49

0¾Tax

Total 1,097.49

· · f)(.'(' "il ;1 ·)ff] Adjuster Bud O'Brien Hourly Rate ($$/hour):::: 51.50 Hours to date ···1s'.11 ····- :·.1

Insured - Payment 781.26

Claimant Mileage (,42/Mile) 120 Mileage Cost 50.40

Claim No. Phone Cost 16.80

Pop.cyNo. -Date of Loss 2/4/2007

Office Cost 13 6.53

Pictures @ 2.25/picture 50 Picture Cost Misc. Cost

·112.50

0.00

00922 '\

Gross Total Date Time (mins)Action Taken

2/5!10 07 15 set up & review new assignment.

2/6/2007 180 travel to loss site, met with the named insured, surveyed d11.mages

0 obtained non waiver, photos

2/13/2007 10 phone call to the insured inspected loss reviewed following drying conditions

0 met with the insured son and Mike Tackman from Maximum Const

2!10/2007 150 phone call to the insured inspected loss reviewed following drying conditions

0 met with. the insured son and Mike Ta.ckman from Maximum Const

105 reviewed file in preparation of estimate repairs & drying


15 reviewed report to carrier

$1,097.49

3/1!1007

3/2!1007

3flfl001

3/2/2007

3/2/2007

3/2/2007

3/3!1007

10 phone call from Gene Ivanoff to go head with.the recommended building & temp settlement

3!11/2007

3!11/2007.

3!16/2007

3/27/2007

3f1Sf1001

4/9/2007

4/12/2007

4/12!1007

4/12/2007

4/18/2007

4f15f1001

4/25!1001

4/25/2007

5!18/2001

5 phone call to the insured no answer left phone message

15 phone call to the insured son Eddie Goer reviewed settlement offer

25 labeled photos

10 phone conversation wjth Gen!' Ivanoff asked that we would call Mrs, Goer

_10 phone conversa~on with--reviewed the settlement :figures

60 prepared sub release, Proof of Loss, and also prepared letter to the insured

10 phone call Maximum Constregarding temp bill

IO fax note to Maximum Const

10 floor company for repair of vinyl tile

10 floor company will repair floor wants to be paid upon completing repair

15 calls to Trevor Miles

10 call to Tackmaa .

15 phone conversation wJth Mike Tackman

30 prepared release to the insured

20 prepared correspondence to the insured

30 prepared correspondene to carrier on the compromise

20 reviewed ~e in preparation of closing report to carrier

910

BILL TO


ITEM DESCRIPTION

Property Loss

milaage · phone office photographs

Tharik you for your business!

~,......,,._ M l

00922

DATE

11/23/12

SHIP TO

Liberty Claim Services, LLC P.O.Box 2064 Brighton, M.ichigan 48114 Phone No: 810-227-0517 or 810-599-1771

DUE DATE

QTY

16,91

180

Subtotal

0% Tax

86

Total

12/23/12

RATE

51.50

0.42

2,25

DFC 2 G ?.013

Invoice INVOICE#

11541

P.O. NUMBER

AMOUNT

870.87

75.60 12.50

152.1.9 193.50

1,304.66

1,304,66

Adjuster

Insured

Claimant

Claim No.

PolloyNo.

DateofLoss

Date

7/11/2007

7/11/2007

7/19/2007

7/2Jn.007

7/23/2007

7/26/2007

8/13/2007

8/13/2007

8/13/2007

8/14/2007

8/14/2007

8/17/2007

8/21/2007

8/28/2007

8n9/2007

· 9/5/2007

9/5/2007

9/5/2007

9/10/2007

9/11/2007

9/11/2007

9/12/2007

9/12(2007

9/12/2007

9/12/2007

9/13/2007

Bud.O'Brien

-7/8/2007

Timc(mins)

Di:C ' 1 I' ?Or !, ; . .')

Hourly Rate ($$/hour}'- Sl.50 Ho~ to date .. 16.91

Payment 870,87

Mileage (.42/Milo) 180 Mileage Cost

00922 75.60 I!

Phone Cost i2.50

Office Cost

and August 6, 2007 Pictures @2.2S/picture 8 6 Picture Cost

Mlso. Cost

Gross Total

Action Token

15 setup & review new assignment

1 O phone conveisation ~lh the insured set up apt

180 !ravel lo loss site, met with Ins~-' obtained Non Waiver sur\'"eyed premises, roof, siding, interior

90 prepared c:stimalc:s w/s interior waler damage, flooring

10 phone call ftom the insured regarding patio furniture

120 reviewed file in prep.ar11tion of report lo carrier

10 phone conveisation with Gene Ivanoff to proceed with the set1lement

5 phone call to the insured left messages both numbers

10 _plione call from the insured unable to ievlew information at the time

10 reviewed settlement recommendations with the insured indicated that we would be seudlng settlement

0 agreement

45 prepared release and letter to the insured

5 phone message ftom lhe insured

l O phone oonvmalion wilh the insured said he 1vould not settle for offer&. had additional water damage living room

18 0 travel m ct with the insured obtained non waiver, ins~ted root inspected llv ing room

10 phone converaalion with Gene. A.dviscd that we hed inspected loss bCllausc of the claim by the insured of

0 additional damages 11re11 of damages on the north side of the home. Unrelated t~ Ute claimed water dameges to the

0 SW comer of en office

45 reviewed file & prepared e.stim ate

75 pn:pRTCd report to Gene Ivanoff

10 label photos

5 message ftom Geno ok to settle claim on living room as recommend lass the deducliblc

5 phone call to the insured left message

15 phone conversation with the insured reviewed settlement on Ille living room discuss other olaim advised company·

0 would not pay any additional on the roof, insun:d debated co replacing, indicated in my opinion dllltlage was

0 rep alrablc illlinred then wanting me lo find II roofing comp to rnakc the repairs

10 pllone conversation with Gene gave him update on the claim. Agreed thatl should locale a contractor to

0 repair roofas recommended and then give !he Insured _and name & phone number to have repaired

S phone call to Gee Construction Dundee left message for Tason

5 phone call to Gee Construction Dundeo !aft message fur Jason

l O phone conversation with the insured Indicated that we would supply name & phone number of roofing 00 to

O repair bat ho would need to schedule and pay them

5 phone call to Cke Conslruotion LTM

19

193.50

0.00

~1,304.66

9114/2007

9114/2007

9114/2007

9/14/).007

9114/2007

9/28/2007

IO phone convertation with Jason Oee. 'fold him that the insu.red shU'lgle was black a11d about 10 roisslng

0 be is wilting to pick up a shlngle from the insured's roof match ns close as possible and replace the mlssing

0 shingles for $280 indlca!t:d that I would cal( back after speaking wllh insured he coUld do the work this afternoon

O on Sat mom tog

5 phone call to the insured Ieft phone message

S phone cal1 to the insured left phone message

45 prepared Jetter to the in:nrrcd with ~!ea~e

30 prepared cor~pondence to Gene Ivanoff

20 prepared closing-report to carrier

1015

00922 \\

Bill TO


ITEM DESCRIPTION

Property Loss

~ t OS , 2007 mileage phone office photographs


OOH22 DATE

11/23/12

SHIP TO

liberty Claim SeJVices, LLC P .O.Box 2064 Brighton, Michigan 48114

DUE DATE

12/23/12

QTY RATE

12.67 51.50

80 0.42

53 2.25

, ... , '

Subtotal

0%Tax

Total

Dr-c· o ,., ,; .1 ,,1 t:, t, O , I • ·1

Invoice INVOICE#

11542

· P.O. NUMBER

AMOUNT

652.51

33.60 4.50

201.50 119.25

1,011.36

1,011.36

Adjuster Bud O'Brien Hourly Rate ($$/hour)= 51.50 Hours to date 12:tuFC ? (: ?nti; Insured - Payment 652.51 · ·-

Claimant Mileage (.42/Mile) 80 Mileage Cost 33.60

Claim.No. Phone Cost 4.50

Policy No. - transcribed recorded interview Office Cost 201.50

Date of Loss On or about February 16, 2007 Pictures @2.25/picture 53 Picture Cost 119.25

Date 2/20/2007

2/20/2007

2/23/2007

3/30/2007

3/31/2007

4/1/2007

4/2/2007

4/13/2007

5/2/2007

5/3/2007

6/6/2007

6/7/2007

6nt2001

6/11/2007

6/11/2007

6/13/2007

Misc. Cost 0.00

00922

-Gross Total $1,011.36

Time (minsAction Taken 15 set up & review new assignment.

10 phone conversation with the insured, set up apt

240 travel to loss location, obtained Non Waiver, obtained R/Statement insured

0 surveyed building

10 phone conversation with Trevor :Miles, transcribe .insured's statement

85 review file in preparation of report

60 review file in preparation ofreport

15 reviow report to carrier


45 reviewed file in preparation ofletter to the insured

25 phone conversation insured, & Gene 1 vanoff OK to send letter to the insured

45 reviewed records from AF & prepared an estimate


10 phone conversation with Gene Ok to follow up with the contractors

0 American Carpet & Keipfer Mechanical

5 phone call to the insured left phone message

10 phone conversation with Nathan from American Carpet tenative apt for

0 6/13 at the loss site

120 travel to loss site met ~vith the insured's contractors.

760

nC('• (J (' r (I U! ):. ' /.' I '/ L {.J

00922 l~ Invoice DATE INVOICE#

11/23/12 11543

BILL TO SHIP TO

American Fellowship Liberty Claim Services, LLC 26001 Telegraph Rd P, 0. Box 2064 Southfield, Michigan 48034 Brighton, Michigan 48114 Attn Trevor Miles Phone No 810-227-0517 or 810-599-1771


12/23/12

ITEM DESCRIPTION QTY RATE· AMOUNT

Property Loss .,._ Date of Loss: April 2007

8.83 51.50 454.76

mileage 60 0.42 25.20 phone 2.00 office 79.66 photographs 30 2.25 67.50

:

Thank you for your business! Subtotal 629,01

0%Tax

Total 629.01

Adjuster

Insured

Claimant

Claim No.

PolicyNo.

Date of Loss

Date 5/17f2007

S/17riOb7

5/18/2007

5/22/2007

5/23/2007

Bud O'Brien DEC !?: G ~;n !]

Hourly Rate ($$/hour)= 51.50 Hours to date 8.83 - Payment 454.75

Mileage (.42/Mile) 60 Mileage Cost 25.20 - Phone Cost 2.00 Office Cost 79.56

April2007 Pictures @ 2.25/picture 3 0 Picture Cost 67. 5 0

Time (mins)Action Taken 15 set up & review new assignment.

20 phone call to the insured contact to set up apt

0 real estate co couple phone conversations

240 travel to loss site, obtained Non Waiver, obtained R/St

0 ~spected dam11ges, prepared scope

75 prepared estimate


530

Misc. Cost o.oo

00922 · ~

Gross Total $629.01

BILL TO

American Fellowship 26001 Telegraph Rd Southfield, Michigan 48034 Attn Tom Pardo

ITEM

No Fault-.Prop Insured :

m!leage phone office photographs

Clalmant: Claim No:


DESCRIPTION

- - - ... __.,,,,

00922

DATE

11/23/12

SHIP TO

Liberty Claim Services, LLC P.O.Box2064 Brighton, Michigan 48114 Phom~ No: 810.227-0517 or 810-599-1771

DUE DATE

QTY

Subtotal

0%Tax

5

45

22

Total

12/23/12

RATE

0.42

2.25

DE·c· C) . . '! : .. ,·-r,J··· h n t.1 t ... U}·

Invoice INVOICJ:#

11544

P.O. NUMBER

AMOUNT

257.50

18.90 2.00

45.00 49.50

372.90

372.90

Adjuster

Insured

Claimant

Claim No.

Policy No.

Date of Loss

Date 7/27/2007

7/30/2007

7/31/2007

8/1/2007

8/6/2007

8/7/2007

8n12001

Bud O'Brien . Hourly Rate ($$/hour)= -- Mileage (.42/Mile) -·· 7/27/2007 Pictµres @ 2.25/picture

Time (mins )Action Taken 15 set up & review new assignment.

10 phone conversation with clalmant made apt

10 confirmed assignment with Tom Pardo

135 travel, met with. claimant, inspection loss site

45 review fileJn preparation of estimate

75 reviewed file in preparation of report

10 labled photos

300

51.50 Hours to date j'p~··, J ' '. s'· o···· ;, :·!,,: .. . . 1:.,

Payment 257.50 45 Mileage Cost 18.90

Phone Cost 2.00 Office Cost 45.00

22 Picture Cost 49.50 Misc. Cost 0.00

-00922 '\

Gross Total $372.90

BILL TO

American Fellowship 26001 Telegraph Rd Southfield, MlcJ,lgan 48034 Attn Trevor Miles

ITEM DE.SCRIPTION

Property Loss



-009.~2

DATE

11/23/12

SHIP TO

Liberty Claim Services, LLC P .0. Box 20B4 Brighton, Michigan 48114 Phone No: 810-227-0517 or 810-599-1771

DUE DATE

QTY

9.58

75

130

Subto@I

0%Tax

Total

12/23/12

. RATE

51.50

0.42

2.25

JJEC 2 6 2013

Invoice INVOICE#

11545

P.O. NUMBER

AMOUNT

493,37

31.50 2.00

85.85 292.50

905,22

905.22

Adjuster

Insured

Claimant

Claim No.

_ PolicyNo.

Date of Loss

Date 6/26/2007

6/26/2007

7/6/2007

7/11/2007

7/18/2007

7/23/2007

7/28/2007

Bud O'Brien Hourly Rate ($$/hour)=

Mileage (.42/Mile) --3/16/2007 Pictures @ 2.25/picture


10 phone call Anita Thomas to set apt for inspection

10 phone conversation with Al Johnson

180 travel to loss site, inspection

51.50

75

130

DFC .'.), H ·:;nn Hours to date 9.58 Payment Mileage Cost Phone Cost Office Cost Picture Cost Misc. Cost

00922

Gross Total

493.37

31.50

2.00

85.85

292.50

0.00 ·l

$905.22

150 review file in preparation of estimate & begining of report to carrier

150 completed review of file in preparation of report to carrier

60 review & label photos

575

/

BILL TO


ITEM·

Property Loss Policy No Claim No

·DESCR

Date of Loss: 3/1/2007 mileage phone office photographs

.......... -...... ·-·---'-----Thank you for your business!

...

IPTION ..... --~

00922

DATE

11/23/12

SHIP TO

Liberty Claim Services, LLC P.O.Box 2084 Brighton, Michigan 48114 Phone No: 810-227-0517 or 810-598-1771

Invoice INVOICE#

11546

---------·-····-········--_)

....... -....... DUE DATE P.O. NUMBER

·-~"--

12/23/12 . __ ,._,

QTY RATE AMOUNT ~ ......... -

7 51.50 360.50

40 0.42 16.80 3.00

62.73 85 2.25 181.25

-·-·-·····-+•••• •·~--•-••-••-·•--•~••-r••• •• ••••

Subtotal 634.28

0%Tax

Total 634.28

C"-Adjuster Bud O'Brien Hourly Rate ($$/hour)= 51.50 Insured

Claimant Mileage (.42/Mile) 40 Claim No. -Policy No. -Date of Loss 3/1/2007 Pictures @2.25/picture 85

Date Time (mins )Action Taken 6/14/2007 15 set up & revfow new assignment

6/14/2007 10 phone conversation with Kim Ratcliff

6/19/2007 IO phone cali from the mortgagor's contractor Kevin will inspect Friday

6/21/2007

· 6/22/2007

7/6/2007

7/7/2007

7/9/2007

0 he wants to call back to confirm

10 phone conversation with Kevin inspection for 6/22

165 travel, conversation with neighbor about vacancy, inspection

165 review file, records from mortgagor in preparation of report to carrier

15 review report to carrier

30 label photos

420

Hours tq,d?,te 7.0.0r·) ·: • ·•1 I

Payment 360.50 Mileage Cost 16.80 Phone Cost 3.00 Office Cost 62.73 Picture Cost 191.25 Misc. Cost 0.00

,. ... .,., ,....._....,, <.,, ',.,.2

Gross Total $634.28

BILL TO

American Fellowship 26001 Telegraph Rd Soulhfie!d, Michigan 48034 Attn Trevor Mites

lTEM

Property Loss


Date of Loss: 2/6/2


~ .. ---·-

007

DESCRIPTION

----~--···•'"-

·····-

00922· . '1 . DEC 2 6 2013


11/23/12 11547

.................... --... - .. --~--·--~ SHIP TO

Liberty Claim Servlces, LLC P.O.Box 2064 Brighton, Michigan 48114 Phone No: 810-227-0517 or 810-599-1771

DUE DATE

12/23/12 ~--~-..,. .. ·----·

QlY RATE ..... _.,.,.,.,..._._, ____

9.83 51.50

230 0.42

50 2.25

P.O. NUMBER

AMOUNT

506.25

96.60 6.00

88.09 112.50

... ···----,• -··· ..... •-..-,~---, .. - -· . ----· -·- ··- ... --Subtotal 809.44

0%Tax ----------

Total 809.44

..

Adjuster

Insured

Claimant.

Claim No.

Policy No.

Date of Loss

Date 2/6/2007

2/7/2007

2/8/2007

2/12/2007

2/15/2007

2/20/2007

2/20/2007

2/21/2007

2/22/2007

2/23/2007

3/9/2007

3/10/2007

fl&. f"\_r.,,, .- ..,. . ..,

Bud O'Brien Hourly Rate ($$/hour)"" 51.50 - Mileage (.42/Mile) 230

2/6/2007 reported Pictures@ 2.25/picture 50

Payment to contractor 1o meet

fl.t the loss site with a ladder to inspect

chimney

Time (mimActionTaken 15 set up & review new assignment.

5 phone call to the insured LTM

5 phone call to the insured LTM

5 phone call to the iusured LTM

10 phone conversation with the insured set apt

,. 'DEC 2 G 2013

Hours to date Payment Mileage Cost Phone Cost Office Cost Picture Cost Misc. Cost

Gross Total

10 phone conversation with Gene Ivanoff OK hiring contractor so I could get on the roof

10 phone conversation with the contractor Roger Jerkovic

5 phone call to t11e insured L TM

10 phone conversation insured confirmed apt

360 travel, met with the i11s11red, obtained non waiver, obtain statement, inspection



590

9.83

506.25 96.60

6.00

88.09 112.50

100.00

00922 I)

$909.44

00922 OFC ?t 13 ?.Oi3 ......... ~ ..... ---

Invoice ....... ---···--·-·--·

DATE INVOICE# ------

11/23/12 11548

-------------~ ....... ----·-·----·-··------,..--------------------, BILL TO

---------------···--···········-··-····· American Fellowship 26001 Telegraph Rd Southfield, Michigan 48034 Altn Trevor Miles

SHIP TO

Liberty Claim Services, LLC P.O.Box 2064 Brighton, Michigan 48114 Phone No 810-227-0517 or 810-599-1771

·---····· .. ······-·····-··---------------<C.---


12123/12 -------------------------~-~-~----- ~----~---·---···---

·1TEM DESCRIPTION QTY . RATE AMOUNT ,___ ____ ....._ _____ ,..,m-•o••r•--•·-------------t------t-------. ,..,._,..__,-~,-·~-----!

Property Loss


... Dale of Loss: 1 /2612007

10.83 51.50

90 0.42

35 2.25

557,75

37.80 5,00

97.05 78.75

1--------'--------------···-······-·····-········---+----._L._ ____ ___j[__ _____ --l Thank you for your business! Subtotal

0%Tax

776.35

,-------------~-···---····-···

·rot~I 776.35

Adjuster

Insured

Claimant

Claim No.

Policy No.

Date of Loss

·Date 1/29/2007

1/29/2007

1/29/2007

2/20/2007

2/7/2007

2/8t2007

2/8t2007

2/8/2007

2/9/2007

2t21/2007

2/24/2007

11/7t2007

ll/8tl007

, ... ,. ... .-..... .Ill.,.....,. I 00922.

Bud O'Brien Hourly Rate ($$/hour)"" 51.50 Hours to date 10.83 - Payment 557.75


1/26/2007 Picrures @ 2.25/picture 35 Picture Cost 78.75 Misc. Cost . 0.00

nrr. ~, ,) ?UYJ '· ' '\) .

Gross Total Time (mins )Action Taken


10 phone conversation insured arranged apt

240 travel to loss site met with the insured obtained non waiver) statement

0 inspection of property

10 ~aragon report relative to their findings

·75 several phone calls with the insuredt met with the insured

75 travel to ERS with property lap top and camcorder

20 phone conversation with Paragon x2 AF authorized ~heir retention

10 phone calls to the insured x 4

10 report :from ERS with their findings

135 reviewed file in preparation of report to carder

20 reviewed photos & labeled

10 call from ERS they indicate tb11t they were not paid for checking out the computer & camera

20 reviewed file in preparation of note to Gene Ivanoff

650

$776.35

BILL TO


00922 'I,

ore?, G znn Invoice DATE

11/23/12

SHIP TO

Liberty Claim Services, LLC P.O.Box2064 Brighton, Michigan 48114 Phone No: 810-227-0517 or810-599-1771

·---INVOICE ff

11549

,__ ________ ............ ·-···--------l!.---------· .. ···· ............. ________ --..J

·------··· -· -····· .. ··--~-·- -...-.-·-·-"·--·-·-·--·-· DU~ DATE P.O. NUMBER

.... _.,_ -···-.. ···-···--·-··-···· ..... --· 12/23/12

ITEM DESCRIPTION QTY RATE AMOUNT . -- ·--~-----.. ~---

Property Loss ~ 6.83 51.50 351.75

Date of Loss: Aprll 2007 mileage 42 0.42 17.64 phone 2.00 office 61.47 photographs 41 2.25 92.25

....... . ,,.._ . ..,._ ·--···-· ................. ., ......... , ... _~--- . ---Thank you for your business! Subtotal 525.11

0%Tax ____ .,_...._ ........... ____ ----····--·-

Total 525.11 .......... -..-.-..

-~-• .,ou,. •••••-·•- •••••·-• """ ._,

,, '"'~ ...a i'\

Adjuster Bud O'Brien Hourly Rate ($$/houi·)= SI.SO ifc091i2dtf b 2 §1-nr ours o t b. · · :i Insured ·- Payment 351.75 Claimant

Claim No.

Policy No.

DateofLoss

Date 4/9/2007

4/9/2007

4/10/2007

4/16/2007

4/16/2007

4/16/2007

4/25/2007

Mileage (.42/Mile)

-4/1/2007 Pictures @ 2.25/picture


10 phone call insured to schedule apt

180 travel to loss site, obtained R/S, inspected claimed damages

42 Mileage Cost Phone Cost Office Cost

41 Picture Cost Misc. Cost

Gross Total

10 phone conversation with Gene asking that we submit report with our findings

45 reviewed file & prepared estimate

135 reviewed file & prepared report to carrier

15 label photos

410

17.64

2.00

61.47

92.25

0.00

$525.11

nno-t a 00922 I

DfC ?, 6 ?fH:~

Invoice

BILL TO SHIP TO -----------J.-----·-··--·--.---------------------1

American Fellowship 26001 Telegraph Rd Soulhfleld, Michigan 48034 Attn Trevor MIies

Liberty Claim Services, LLC P.O.Box 2064 Brighton, Michigan 48114 Phone No 810-227-0517 or 810-599-1771

----------- ·-·········--·-----------'

-~-·-··-- ........... DUE DATE P.O. NUMBER

----·· ·----· 12/23112

·---~-· ·-·-·- ----··----- .. --·-···-··--··-·--·-~ ITEM DESCRIPTION QTY RATE' AMOUNT

--···-·- ______ .. _____ ,_.,._,. __ -·-· Property Loss ....... 6.5 51.50 334.75

Dale of Loss: March 4, 2007 mileage 60 0.42 25.20 phone 5.00 offiGe 58.48 photographs \ 45.00

.-h ... ~ ----··---·-Thank you for your business! Subtotal 468.43

0%Tax ---- ~~--~-- ......... ~.

Total 468.43

----...-.------------~-------·

Adjuster

Insured

Claimant

Claim No.

Policy No.

Date of Loss

Date 3/13/2007

3/13/2007

3/14/2007

3/14/2007

3/15/2007

3/16/2007

3/16/2007

3/16/2007

3/19/2007

4/4/2007

"'"l)b§z2 Bud O'Brien Hourly Rate ($$/hour)= 51.50 Hours to dijt& 2 6 &.%'18

Payment Mileage (.42/Mile) 60 Mileage Cost

Phone Cost - Office Cost Reported March 04, 2007 Pictures @2.25/picture 20 Picture Cost

Misc. Cost

Gross Total Time (mins)Action Taken


150 phone conversation with insured set up inspection 3/13; travel inspection

30 prepare estimate


20 phone conversation with contractor

0 asked that lie would fox the breakdown for the plumbing

10 phone convenmtion with Gene Ivanoff, he extended settlement authority

10 phone conversation with the insured made settlement offer

30 reviewed file in preparation ofrcport to CHrrier

30 prepared settlement agreement & correspondence to the insured

20 report to carrier with signed settlement agreementrequesting check

390

334.75

25.20

5.00 58.48

45.00

0.00

$468.43

BILL TO

American Fellowship 26001 Telegraph Rd Southfield; Michigan 4B034 Attn Trevor Miles

-0~~~)1.'C' C~ ,··, ,- .• _.:., I • \ ' / t) r. l\ 1 ;l

Invoice ·····- -·---·-·-·-·-·-·g DATE INVOICE#

11/23/12 11551

SHIP TO

Liberty Claim Services, LLC P.O.Box 2064 Brighton, Michigan 48114

+~••-•ma••••-·•'•"-•""""'- .,-,..,,ra,,_ •

Phone No 810-227-0517 or B10-599-1771

-------·---···------·-------,"-----~

--··- ··········---·-DUE DATE P.O. NUMBER

............ 12/23/12

ITEM · DESCRIPTION QlY ·.RATE AMOUNT --···-------·-

Property Loss 5.42 51.50 279.13 Poficy No Date of Loss: July 29 & August 28, 2006

mileage 75 0.42 31.50 phone 1.00 office 48.57 photographs 45 2.25 101.25

'

--· ••no•_,..,,.y,p••••~•--• ---·····-·· ... -···--·--Thank you for your business! Subtotal 461.45

0%Tax ·--

Total 461.45 _ ... -.. ~--·--··-··· .. ··-·--· --·····-------·-·

Adjuster

Insured

Claimant

Claim No.

Policy No,

Date of Loss

Date 8/30/2006

8/30/2006

9/6/2006

9/19/2006

uu~;,;2

Bud O1Brien Hourly Rate ($$/hour)= 51.50 Hours tor~a}"-~ ~2.4ri1 - Payment····-Mileage ( .42/Mile) 75 Mileage Cost

Phone Cost - Office Cost Reported July 29 & August 28, Pictures @ 2.25/picture 45 Picture Cost

Misc. Cost


15 set up & review new assignment

10 phone conversntion with the insured & setup appt

195 travel to loss site, met with the insured, obtained Non Waiver Agreement & statement

105 review file in preparation of report to carrier on two claims

325

279.13

31.50

1.00

48.57

101.25

0.00

$461.4S

BILL TO


··-·--··-···------------

ITEM

Property Loss



DESCRIPTION

6,2007

009~2 .... ..,,. ____ ,..,_,._

SHIP TO

Liberty Claim Services, LLC P.O.Box 2064 Brighton, Michigan 48114 Phone No: 810-227-0517 or810-599-1771

111:c z 0 2nn' Invoice·

--·---·--·--·-··----,-----------, DUE DATE P.O. NUMBER ______ .,. _____ ·---------l

12/23/12

QTY · RATE AMOUNT -----+-----+-----------···· ······-·----·-·····------

7.08

Subtotal

O%Tax

60

17

Total

51.50

0.42

2.25

364.62

25.20 4.00

63.72 38.25

495.79

495.79

---------------·-·-··-···-------~-----

() n,,-. 'VU~~~

Adjuster Bud O'Brien Hourly Rate ($$/hour)= 51.50 Hours t<jJf!~ 2, @> l.::ll'(1J08 -Tusured Paymenr Claimant Mileage (.42/Mite) 60 Mileage Cost Claim No. Phone Cost

Policy No. Office Cost Date ofLoss 4/16/2007 Pictures @ 2.25/picture 17 Picture Cost

Misc. Cost

Gross Total

Date Time (mins) Action Taken

·4/25/2007 15 set up & review new assignment.

4/25/2007 l 0 phone contact with the insured apt made

4/30/20D7

5/1/2007

5/2/2007

5/11/2007

5/11/2007

5/23/2007

5/23/2007

180 travel to the 1nsured location, met with tbe insured, inspected roof system



10 phone conversation with carrier aulhorized settlement for $770.61

10 phone conversation with the insured regarding settlement offer

30 prepared proof of loss & letter to the insured

10 Gene wants me to call the insured to confirm that the insured

0 is withdrawing the claim

10 phone call with the insured he has had roof repaired and he wants to withdraw the

0 claim

425

364,62 25.20 4.00

63.72 38.25

0.00

$495.79

BILL TO

American Fellowshlp 26001 Telegraph Rd Southnetd, Michigan 48034 Attn Trevor Miles

... -ITEM

Property Loss .... Date of Loss: 6/1/2007


----·" - ....... ___


-.. .....

......

DESCRIPTION

·----~·--·-·

_ , ... , •• d

,Ji-- 'l~ '/_, (;- '(.t!'i':'· I~ ~

.~ ·~ Invoice DATE

12/31/12

SHJPTO

Liberty Clallm SeNices, LLC P.O.Box 2064 Brighton, Michigan 48114 Phone No: 810-227·0517 or 810-599-1771

E"UEDATE P,O, NUMBER

1/30/13 ..., ___

QTY RATE AMOUNT ----

..

- ··-- .... _ 4.5 51.50 231.75

45 0.42 18.90 2.00

40.50 16 2.25 36.00

......... ··--.. ......... ... Subtotal 329.15

0%Tax -·

Total 329.15 ___ ,,. ____ .......

. 00922 Dt.C?., 6 ~\1 d Adjuster Bud O'Brien Hourly Rate ($$/hour)= 51.50 · ours to ate .

Insmed - Payment Claimant Mileage (.42/Mile) 45 Mileage Cost Claim No. Phone Cost Policy No. - Office Cost DateofLoss 5/1/2007 Pictures @2.25/picture 16 Picture Cost

Misc. Cost

Gross Total · Date Time (mins)Action Taken

5/14/2007 15 setup & review new assignment.

5/14/2007 10 phone coi,versation with the insured arranged inspection

5/17/2007 135 travel, metwitb. the insured, inspected roof system

5/19/2007 · 30 review file & prepared estimate

5/21/2007 10 cell from Gene Ivanoff regarding our findings advised and indicated we

5/22/2007

5/22/2007

0 would have report to him on 5/22


JO label photos

270

4.50

231.75 18,90

2.00

40.50

36.00

0.00

$329.15


12/31/12 11556

----------------------------··-··"···-----·---·---

American Fellowship 25925 Telegraph Rd Suite200

BILL TO

Southfield, Michigan 48033 Attn Trevor MIies

ITEM

Property Loss Insured: Policy NO:

DESCRIPTION


SHIP TO

Liberty Claim Servlces, LLC. P.O.Box 2064 Brighton, Michigan 48114 Phone No 810-599-1771

DUE DATE

1/30/13

QTY RATE

4.75 51.50

40 0.42

12 2.25

P.O. NUMBER

AMOUNT

244.63

16.80 5.50

42.74 27,00

·-···-----------L------------------"··-·------------1-----1....-___ __1, ______ ___J

Thank you for your business I Subtotal

0%Tax

·Total

336.67

336.67

Adjuster

Insured

Claimant

Claim No.

Policy No.

Date of Loss

Date 11~/2006

11/2/2006

11/4/2006

11/6/2006

11/6/2006

11/28/2006

11/30/2006

1/3/2007

1/20/2007

1/24/2007

1/25/2007

1/27/2007

Bud O'Brien Hourly Rate ($$/hour)= - Mileage (.42/Mile)

-10/2/2006 Pictures @ 2.2 S/picture

Time (mins )Action Taken 15 set up & review new 11ssignmenl.

5 call to the insured left phone message

5 call to the insured left phone message

5 eall to the insured left phone message

10 phone call insured set apt

120 travel, inspection ··

10 phone call to the insured discuss leaking condition

51.50

40

12

10 phone conversation with the insured she taped drain no signs

0 ofleaking, she removed access panel no signs of leaking

0 when shower head is on then leaking is occurring



)"•!''!'·· f\) () r•r Ii. · ~2· · :-Ho~~·~\~' <l~t~: ~qg, . Payment 244.63 Mileage Cost 16.80 Phone Cost 5.50 Office Cost 42.74 Picture Cost 27.00 Misc. Cost 0.00

Gross Total $336.67

l 0 per phone conversation with Gene Ok to proceed with the settlement as recommend

5 label photos

285

American Fellowship 25925 Telegraph Rd Suite 200

BILL TO

Southfield, Michigan 48033 Attn Trevor Miles

DEC 2 6 20\3

DATE

12/31/12

SHIP TO

Liberty Claim SeJVices, LLC P.O. Box 2064 Brighton, Michigan 48114 Phone No: 810-599-1771

.. 00922

Invoice INVOICE#

11557

~---------- .. ······---·--·--------__._ ____________ , ................ ~-··-~#~·-----------······-~-----·~·

____ _...,,-~--

ITEM · DESCRIPTION

Property Loss Insured:......._ PollcyN~


Date of Los s: 12/25/2006

·--···----· ··--·-~

.............. _ .......

···-~---···· ·-·----·-


1/30/13

QlY RATE AMOUNT

6.3 51.50 324.45

30 0.42 12.60 4.00

56.68 30 2.25 67.50

··-~·-·- ... ......... ········- ~,. . ······· ............ .. ------........ -....

Subtotal 465.23

O¾Tax

Total 465.23

_ · cs~fi.:;~.G Adjuster Bud O'Bden Hourly Rate ($$/hour)= 51.50 t\fC P18J1~~0 ~~.v o,JU Insured ··- Payment 324.45 Claimant Mileage (.42/Mile) 30 Mileage Cost 12.60 Claim No. Phone Cost 4.00 Policy No. - Office Cost 56.68 Date of Loss On or about December 25, 2006 Pictures@ 2.25/picture 30 Picture Cost 67.50

Misc. Cost 0.00

Gross Total $465.23 -Date Time (mins)Action Taken

2/21/2007 J 5 set up & review new assignment.

2/21/2007 10 phone conversation insured set apt

2/26/2007 l 80 travel, met with the insured, obtain Non Waiver, statement iosured & inspection

4/25/2007 90 TI?View file, estimate prep and report to carrier

4/27/2007 IO phone conversation with the insured discuss settlement approved by carrier

5/4/2007 45 prepared correspondence to the insured Rnd policy release

0 with Ps to carrier

6/11/2007 30 prepRred closing report to carrier

380


BILL TO


..-- 00922 D:~C 2 G 2013

Invoice DATE

12/31/12

SHIP TO

Liberty Claim Services, LLC P. 0. Box 2064 Brighton, Michigan 48114

INVOICE#

11558

·--··-·····----------······-···-·-·--------L---------~---

ITEM DESCRIPTION

Property Loss Insured:


Polley No: Date of Loss: 11/30/2006


1/30/13

QTY RATE AMOUNT

4.92 51.50 253.38

60 0.42 25.20 1.00

44.27 36 2.25 81.00

---------1----..L.....-·----·-···--· .... --·-····- ... , ......................... . Thank you for your business!

'--------·············-----.....!..------

Subtotal

0%Tax

Total

404.85

404.85

Adjuster

Insured

Claimant

Claim No.

Policy No •.

Date of Loss

Date 12/1/2006

12/4/2006

12/6/2006

12/23/2006

12/27/2006

12/28/2006

Bud O'Brien Hourly Rate ($$/hom 51.50 - Mileage (.42/Mile)

-reported 11/30/2006 Pictures @ 2.25/pictt

Time (mins)Action Taken 15 setup & review new assignment.

10 phone conversation with the insured apt to inspect

135 travel, inspection loss site, discuss with the insured



60

36

45 review file in preparation of completing report to carrier

295

00922D!:C 2 6 2013 Hours to date 4.92 Payment 253.38 Mileage Cost 25.20 Phone Cost 1.00 Office Cost 44.27 Picture Cost 81.00 Misc. Cost 0.00

Gross Total $404.85 '\

--·--····-··"'-·-·'·'"" .... _ BILL TO

"•••••,r-r_..·,.--••••-,•.-•r•••--•••


ITEM DESCRIPTION



Policy No: Dale of Loss: 1/14/2007


(j{j~J22 -· ··-- ·. ), G '?.0131


12/31/12 11559

SHIP TO

Liberty Claim SeTVices, LLG P.O.Box 2064 Brighton, Michigan 48114

·--·- ................. --··- --· ---·--···-- ----·-·· __ _. _________

DUE DATE

QTY

10.25

Subtotal

0%Tax

44

57

Total

1/30/13

RATE

51.50

0.42

2.25

P.O. NUMBER

AMOUNT - ........ -~·--···---·-

527.88

18.48 5.50

91.85 128.25

771,96

771.96

---~----........................ --~------

Adjuster

Insured

Claimant

Claim No.

Policy No.

Date of Loss

Date 1/15/2007

1/15/2007

1/17/2007

3/13/2007

3/14/2007

3/17/2007

3/21/2007

3/23/2007

3/26/2007

3/26/2007

3/28/2007

4/5/2007

5/5/2007

Bud O'Brien Hourly Rate ($$/hour)= 51.50 -·- Mileage (.42/Mile)

-1/14/2007 ' Pictmes @ 2.25/picture


10 phone conversation with the insured arranged apt

120 travel to loss site & inspection

44

57

135 travel to loss site met with the insm·ed contractor Maple Ridge

5 fax estimate from insured's contractor

75 prepared estimate of damages


15 phone conversation with the insu!'ed's contractor conveyed the

0 settlement figures authorized by Gene Ivanoff

45 prepared Proof of Loss and letter to the insured

20 labeled photos

10 returned call to contractor

15 phone conversation. with Gene Ivanoff also discuss Russell file

DEC 2 6 2013 009~2 · Hours to date 1 .25

Payment 527.88 Mileage Cost 18.48 Phone Cost 5.50 Office Cost 91.85 Picture Cost 128.25 Misc. Cost 0.00

Gross Total $771.96

30 review correspondence from the insured iLl preparation. of memo to carrier

615

...... ;...,_ ........ .-. n

00922 t'.'


12/31/12 11561

-----------------·-------··- ........ , __ ....,...._,_, __ .. ,.,. _________ _ BILL TO SHIP TO

1-----------------------··········--··- "-···-·-·-··.-···-····"·······-·-··-----···-·-··- ·· .. ·-·--·--·---·-··"·····- ····--···--·---·-·-·--·· American Fellowship 25925 Telegraph Rd Suite 200 Southfield, Michigan 46033 Attn Trevor Miles

ITEM DESCRIPTION

Liberty Claim Seivices, LLC P.O.Box 2064 Brighton, Michigan 48114 Phone No: 810.599-1771

-----~·---·-······--------DUE DATE P.O. NUMBER

1----------- -···----·-----------1 1/30/13

QTY RATE. AMOUNT 1----·------·-···---·-··-----=====:----------+----··-··-·-··------+--------~ Property Loss



9.83

200

Subtotal

0%Tax

63

Total

51.50

0.42

2.25

506.25

84.00 3.60

88.47 119.25

801.57

801.57

Adjuster Bud O'Brien Houtly Rate ($$/hoUJ

Insured -·-Claimant Mileage (.42/Mile) 200 Claim No.

Policy No,

Date of Loss Reported October 19, 2006 [email protected]/pict1 53

Date 12/5/2006

12/5/2006

12/8/2006

12/18/2006

12/18/2006

1/12/2007

1/12/2007

1/13/2007


10 phone conversation with the insured apt for 12/8

180 travel to lnsmed location found part of roof snow covered

0 will need to re inspect

10 phone conversation with the insured to inspect tl1e loss

240 travel~ discussion with the insured1 inspection, photo loss

0 discussion with the insured

45 prepared estimates

75 reviewed file ill preparation ofrepo1t to carrier

15 label photos

590

Payment 506.25 Mileage Cost 84.00 Phone Cost 3.60 Office Cost 88.47 Picture Cost 119.25 Misc. Cost 0,00

Gross Total $801.57

~~ ..... --- 'C0,· .. ,.·1.·; 00922 \! :[ , !• (; /.U; ,I

Invoice ~--~~----··-····•• .............. .

DATE INVOICE# ---1

12/31/12 11562

--.. ····-····---···--------------------------BILL TO SHIP TO

--,--------------1,-------------·--····--------American Fellowship 26925 Telegraph Rd Suite 200 Southfield, Michigan 48033 Attn Trevor Miles

liberty Claim Seivices, LLC P.O.Box2064 Brighton, Michigan 48114 Phone 810-599-1771

---------L.. ................. --------

... ITEM DESCRIPTION

Property Loss lnsu Pol Dal

red:~ icy No: e of Loss: 1/25/2006


Thank you for your bu

---~---

..... sinessl

··-

.. _

...

--···

... .. .

...................... , __

DUE DATE P.O. NUMBER ~----··---

1/30/13 -- -------

Q1Y ·RATE AMOUNT .. .. 6.75 51.50 347.63

112 0.42 47.04 2.00

60.49

. .. --· ... ,_,..___,w·•--•-

Subtotal 457.16

0%Tax

Total 457.16

... .... ----------~--·----

00922 OEC ?.1 0 70\3 Adjuster Bud 0 1Brien Hourly Rate ($$/hour)= 51.50 Hours to date 6. 75

Insured 1111111 Payment 347.63 Claimant Mileage (.42/Mile) 112 Mileage Cost 47.04 Claim No.

PolicyNo. -

Date of Loss 1/25/2006 reported [email protected]/picture

Date 6/13/2006

6/13/2006

6/15/2006

6/19/2006

6/22/2006

6/22/2006

Time (mins )Action Taken 15 reviewed file & set up

10 phone ca 11 to the insured apt for 6/15

210 travel, inspection, non waiver /statement .insured

60 prepare estimate


20 label photos

405

53

Phone Cost 2.00

Office Cost Picture Cost Misc. Cost

60.49

119.25

0.00

Gross Total $576.41

BILL TO


ITEM

Property Loss Insured: Claim No Policy No:

----~-----!.-

DESCRIPTION

Date of loss: 2/20/2007 mileage phone office photographs


( 009221i l; DEC ~ G 2013 Invoice

DATE

12/31/12

SHIP TO

INVOIC~~

11563~

--------Liberty Claim Services, LLC P.O.Box 2064 Brighton, Michigan 48114 Phone No: 810-599-1771

DUE DATE .

1/30/13

P.O. NUMBER -·------·--~--'

QlY ·RATE AMOUNT -

5.67

40

80

---· Subtotal

0%Tax ,____

Total

---51 .50

0 .42

2 .25

292,01

16.80 2.00

50.81 180.00

--- -~L.... --- -~----·.

541.62

641,62 , ______________ _

···--··· -~--,-

Adjuster Bud O'Brien Hourly Rate ($$/hour)= Insured -Claimant Mileage (.42/Mile) Claim No. -Policy No. -· DateofLoss on or about Febniary 20, 2007 Pictures @ 2.25/picture

Date Time (mins)Action Taken 6/14/2007 15 set up & review new assignment.

6/14/2007 10 phone conversation with Home Loan Services

6/15/2007 lO phone conversation with Mike Lindsey set up apt

6/20/2007 185 travel to the loss site met with Mike Lindsey,

7/5/2007 120 reviewed file in prep11ration of report to carrier

340

0092% DEC 2 6 2013 51.50 .. ours to date S:67

Payment 292.01 40 Mileage Cost 16.80

Phone Cost 2.00 Office Cost 50,81

80 Picture Cost 180.00 Misc. Cost 0.00

Gross Total $541.62

I' ,., ,.,, ~ n.._...._ ·:

OOH22· I\ • IJEC 2 s 2013 ~ --~


12/31/12 11564

------------------~---------····--------------, BILL TO SHIP TO

---------------·--·--·----··--l.---------------------1 American Fellowship 25925 Telegraph Rd Suite 200 Southfield, Michigan 48033 Attn Trevor MIies


'-c------· ------......................... -----------1.----------····· .. ·-- ---·-·--------'

, .. DUE DATE

ITEM DESCRIPTION QTY 1----- ---+----------------'----··----·-··· ....

Property Loss Insured:~

mlleage phone office photographs

'-·---

PollcyN~ Dale or Loss: 11/26/2006


6.75

117

... Subtotal

0%Tax

27

Total

1/30/13 -

RATE --~~-M-,0 .. o

51,50

0.42

2.25

. ... •••&

P.O. NUMBER

A

-

MOUNT

347.63

49.14 3.00

60.75 60.75

521.27

521.27

Adjuster Bud O'Brien Hourly Rate ($$/hour)= 51.50 Insured -Claimant Mileage (.42/Mile) 117 Claim No.

Policy No. -Date of Loss 11/26/2006 Pictures @ 2.25/picture 27

Date Time (mins)Action Taken 12/4/2006

12/4/2006

12/8/2006

12/15/2006

1/20/2007

1/27/2007

1/27/2007


lO phone call insured set up apt

240 travel to insured, obtain Non Waiver, inspection crawl space

10 correspondence Signal Bldg

45 review file & prepare estimate


10 label photos

405

/II -T ,;.: ,:.' -2ri-:,; · ~ • · · \} .. I, i ..J

Hours to date 6.75 Payment 347.63 Mileage Cost 49.14 Phone Cost 3.00 Office Cost 60.75 Picture Cost 60.75 Misc. Cost 0.00

Gross Total $521.27

OG922 1'.

0(. .::.J _, .1 I\..

M • • •• , ...... ••• ,...,., .. _ - -00922 I'. I j" [:· ('' ~), i'."j 1·1 ""I

·• , •· V r, .l,1


12/31/12 11565

-----·--------------.---~--------------------,


BILL TO

Southfield, Michigan 46033 Attn Trevor MRes

SHIP TO

Liberty Claim Services, LLC P.O.Box2064 Brighton, Michigan 46114

L..-_________________ ...__ ____________________ ,_. __________ _

ITEM DE~CRIPTION !-------+-----------·--- --------Property Loss

· mileage Insured:

phone office photographs

Policy No: Date of Loss: 9/01/2006


DUE DATE

QTY

5.42

Subtotal

O%Tax

40

45

Total

1/30/13

RATE

51.50 0.42

2.25

P.O. NUMBER

AMOUNT

279.13 16.60

3.00 48.57

101.25

448.75

446.75 "-------~-·----- ---- __________ ..1._ __________ ----

Adjuster

Insured

Claimant

Claim No.

Policy No.

Date of Loss

Date 9/1/2006

9/6/2006

9/8/2006

9/23/2006

1/27/2007

1/27/2007

Bud O1Brien Hourly Rate ($$/hour)""' - Mileage (.42/Mile)

-reported . September O I J 2006 Pictures @ 2.25/picture


10 phone call insured set up apt

51.50

40

45

150 travel to .insured, obtain Non Waiver, inspection crawl space


90 reviewed.file in preparation of report to carrier

15 label photos

325

00822-.no~·o ,,

Hours to date 5.42 · ''·I '

Payment 279.13 Mileage Cost 16.80 Phone Cost J.00 Office Cost 48.57 Picture Cost 101.25 Misc. Cost 0.00

Gross Total $448.75

---··-·------------BILL TO

American Fellowship 25925 Telegraph Rd Suite 200 Southfield, Michigan 48033 Attn Trevor MIies

ITEM

Property Loss

phone office

--------

DESCRIP.TIO N

Invoice DATE INVOICE# E-·-·-·-3 ·-·-· ------.. -·

12/31(12 11566 --- ---·

-------SHIPTO

Liberty Claim Services, LLC P .O.Box 2064 Brighton, Michigan 48114

----·-----

DUE DATE

1130(13

C\I"\Af"""i~·r~ \~:it'' .. ,,...,,·!) \J\.J~~ . ... , ~) t~l.} },)

---·. -----P.O. NUMBER -- ,....

QlY RATE AMOUNT.

1.25 51.50 64.38

2.00 11.20

______ _._ ________ _ -·-----........-·-·- #-·· .............. -·- -·---~~~.L....-n-•---

Thank you for your business! Subtotal 77.5 8

0%Tax --·-

Total 77.5 8

00922 '

Adjuster Bud O'Brien Houl'ly Rate ($.$/hour)= 51.50 Hours to date 1.if 2 6 ZOf Insured - Payment 64.38 Claimant Mileage (.42/Mile) Mileage Cost 0.00 Claim No. Phone Cost 2.00 Policy No. - Office Cost 11.20 Date of Loss 10/25/2006 Pictures @·2.25/picrure 0 Picture Cost 0,00

Misc. Cost 0.00

Gross Total $77.58 Date Time (mins)Action Taken


11/6/2006 10 phone conversation insured

11110/2006 t 0 insured called cancelled inspection for today

5/3/2007 10 Gene Ivanoff requested that we send a letter to the insured to see ifwe can

5/4/2007

0 reschedule the apt

30 reviewed file in preparation of letter to the insured

75

BILL TO SHIP TO

\; . .J•; ... - -

00922 nEc 2 6 2013

Invoice

American Fenowship 25925 Telegraph Rd Suite 200

·------i.-----·-·----------------1


Liberty Claim SeNices, LLC P.O.Box 2064 Brighton, Michigan 48114 Phone No: 810-599-1771

'--------------··········--·----'"-------

-------·-----~-----------ITEM DESCRIPTION


mffeage phone office photographs

Claim No: Policy No: Date of Loss: 5/15/2007

~--···-·········· .. ,. _______ _ DUE DATE P.O. NUMBER

1-----~---··-~--·------1 1130/13

_______ ...L._ ____ __,__~~·~--··---·-··-······

QTY

6.08

42

37

RATE:

51.50

0.42

2.25

AMOUNT

313.12

17.64 5.00

54.48 83.25

1---------'-----------------·--···---.................... ·-----L ____ _..1.. ______ j


'.~·

Subtotal

0%Tax

Total

473.49

473.49

Adjuster

Insured

Claimant

Claim No.

Policy No;

DateofLoss

Date 6/13/2007

6/13/2007

6/14/2007

6/16/2007

6/18/2007

6/18/2007

6/26/2007

6/26/2007

6/26/2007

6/27/2007

6/28/2008

.. ~ .. - - . --··- - .. ~ ---.. ~~~

00~22 . .::.C 2 G 2013 Bud O'Brien Hourly Rate ($$/hour)= 51.50 Hours to date 6.08 · · - Payment

Mileage (.42/Mile) 42 Mileage Cost - Phone Cost - Office Cost 5/15/2007 [email protected]/picture 37 Picture Cost

Misc. Cost

Gross Total Time (mins:Action Taken


10 phone contact with the insured arranged iospootion

135 travel, inspection, discussion with insured

45 prepared repair estimate


15 label photos

10 phone call from Gene Ivanoff to go ahead with the settlement as 1'ecomme11ded

5 phone call to-not available left phone message

15 caUed insured home number spoke with- reviewed settlement with her

0 she was extremely roded

10 returned phone call of-reviewed settlement recommendations

30 prepared letter to the insured and Proof of Loss cc to carrier

365

313.12

17.64 5.00

54.48

83.25

0.00

$473.49

BILL TO


ITEM DESCRIPTION

Property Loss Insured:~ Policy No: Date of Loss: 1210 /2008



-~·-·

.................. '

DEC 2 6 2013 Invoice

------------··:a DATE INVOICE# 1--------1----

12/31/12 11568 ...._ __ ~L-...--

SHIP TO

Liberty Claim Services, LLC P.O,Box 2064 Brighton, Michigan 48114 Phone No: 810-599-1771

_____ .......... _ DUE DATE P.O. NUMBER

---.---··· -----1/30/13

-----· --···"-QlY · RATE AMOUNT

~ .............. ....... ·--···· 5,5 51.50 283.25

24 0.42 10.08 2.00

49.29 14 2.26 31.50

---· ..... _.. ....... ,. __ Subtotal 376.12

Oo/oTax

Total 376.12

... ,_ ... ,__. ....

Adjuster Bud 0 1Brien Hourly Rate ($$/hour)= 51.50

Insured

Claimant . Mileage (.42/Mile) 24

Claim No.

Policy No. -Date of Loss reported December 01, 2006 Pictures @ 2,25/picture 14

Date Time (mirnAction Taken 3/26/2007 15 set up & review new assignment.

3/26/2007 10 phone conversation insured arrange fospection

4/5/2007 100.travel to loss site, discussion with insured, inspection

4/5/2007 90 reviewed file in preparation of report to carrier

4/14/2007 30 prepared estimate regarding repairs to bath room

0 0922 . DEC 2 6 2011

Hours to date 5.50

Payment 283 .25 Mileage Cost 1 o. 08

Phone Cost 2.00

Office Cost 49 .29 Picture Cost Misc. Cost

Gross Total

31.50

0.00

$376.12

4/26/2007 IO phone conversatition with Mr. Handy asking that we would submit our report

0 and findings as the insured has called eo for a decision

4/26/2007 75 reviewed file in preparation ofreport to ca1Tier

330


BILL TO

Southfield, Michigan 48033 Attn Trevor Milas

ITEM DESCRIPTION



Policy No: Date of Loss: 3 5 2007


00922 nr:·r 9 i': .-,1···'·) .. l:.l, .1 IJ I_ ! [-J.

111v.oice ----······ .. ·- ----~

DATE

12/31/12

. SHIP TO

Liberty Claim Services, LLC P .0.Box 2064 Brqihton, Michigan 48114

DUE DATE

1/30/13

Q1Y

3.83

RATE

60

Subtotal

0%Tax

Total

5

51.50

0.42

2.25

INVOICE#

11569

P.O. NUMBER ---

AMOUNT ......

197.25

25.20 2.00

34.32 11.25

. 270,02

---

270.02

....... , ..

00922 1: lJ-··· :~ '.,, .. , ... . _L..L '--· ~.'.l d· . ·.

Adjuster Bud O'Brien Hourly Rate ($$/hour)= 51.50 Hf)l~l~ff. _,gate 3. 83 ·, ·' · Insured - Payment 197.25 Claimant Mileage (.42/Mile) 60 Mileage Cost 25.20 Claim No. Phone Cost 2.00 Policy No. - Office Cost 34.32 Date of Loss repored 3/5/07 Pictures @ 2.25/picture 5 Picture Cost 11.25

Misc. Cost 0.00

Gross Total $270.02 Date Time (mins )Action Taken


4/11/2007 10 phone convers11tion with the insured set up apt

4/17/2007 120 travel, discussion with insured, obtain non waiver &

0 inspected claimed area

4/17/2007 20 prepared estiamte

5/25/2007 60 review file ln preparation of report to carrier

5/25/2007 5 label photos

230


BILL TO

South.field, Michigan 48033 Attn Trevor Miles

Invoice

t---1-::-~-;-2 ___ IN;~:# I

SHIP TO

Liberty Claim Services, LLC P .O.Box 2064 Brighton, Michigan 48114 Phone No; 810-599-1771

--------···-··-----------------11....-----

············--DU~ DATE P.O. NUMBER

1/30/13 --·

ITEM DESCRIPTION QTY -

RATE AMOUNT ..... , .. ___ ................ ff ......... -- --•••••M•

Property Loss lnsuted:K 8.83 51.50 454.75 Claim No: Policy No: Date of Loss: 1 2007

mileage 120 0.42 50.40 phone 5.00 office 79.13 photographs 12 2.25 21~00

'

......... ,., ___ ................... Thank you for your business! Subtotal 616.28

0%Tax ---............. -·

Total 616,28

·- I ...

0092~

Adjuster Bud O'Brien Houdy Rate ($$/hour)= 51.50 Hours to date I l 1 : 1 ·8 :ki Insured - Paymertt C .c

Claimant Mileage (.42/Mile) 120 Mileage Cost Claim No. - Phone Cost Policy No. - Office Cost Date of Loss rep01ted April 16, 2007 Pictures @2.25/picture 12 Picture Cost

Misc. Cost

Gross Total Date Time (mins)Action Taken


4/24/2007 IO spoke with the insured arranged inspection

4/27/2007 135 travel to loss site, my }adder would not reach the roof & tarp on roof system

5/2/2007

5/4/2007

5/4/2007

5/4/2007

5/4/2007

5/11/2007

5/11/2007

5/11/2007

5/14/2007

0 call to Company spoke with Gene Ivanoff will inspect with contractor

165 travel to loss site, inspected roof system with contractor, the roof system is in

0 an extremely deteriorated condition


90 review file in preparation ofrepott to carrier

15 review file correspondence to carrier and enclosures

10 label photos

10 phone conversation with Gene Ivanoff wanted to know the cost of tile

0 temps

10 I called tony s.ince I did not have the file. He indicated a price of

0 1037.76

10 phone conversation with Gene Ivanoff gave him the quote from Tony

30 reviewed file provided correspondence to Gene Ivanoff on tile temp charges

530

454.75

50.40

5.00

79.13

27.00

0.00

$616.28

- - -· .. -.,....,,_.

00922

1--1-:-:T-1~-12--1---I-NV_1 ~-;-~~ # --J BILL TO · .SHIPTO

1----·------ ~-------American Fellowship 25925 Telegraph Rd Suite 200

1,------------- -----------1

Southfield, Michigan 48033 Attn Trel/or Miles

ITEM DESCRIPTION

Property Loss insured:---Claim No: Date of Loss: 10/1/2006


~-··-··· __ _. ........ Thank you for your business!

........... - - -----

···- ····· ·····•

Liberty Claim SeNices, LLC P.O.Box2064 Brighton, Michigan 48114 Phone No: 810-599-1771

DUE DATE

1/30/13

QTY RATE

6.92 51.50

35 0.42

70 2.25

_ ....... -..........

P.O. NUMBER ........ -----·--·· --..

__ , ............... --.-AMOUNT

..... ~ .... 356.38

14.70 7.00

62.01 157,50

. ......... ~-- -~-Subtotal 597.59

0%Tax ·-········-·· .. ·-·--~---

Total 597.59 .....

Adjuster

Insured

Claimant

Claim No.

Policy No,

Date of Loss

-Date 11/21/2006

11/22/2006

11/28/2006

12/5/2006

12/21/2006

12/28/2006

1/13/2007

1/18/2007

1/18/2007

1/19/2007

1/19/2007

1/25/2007

1/27/2007

uuc,;c;~ (10--· .,, )

Bud O'Brien Hourly Rate ($$/hour):::= 51.50 Hours to date 6.92 Payment 356.38

Mileage (.42/Mile) 35 Mileage Cost· 14.70 -10/1/2006 Pictures @ 2.25/picture

Time (rnins)Action Taken 15 set up & review new assigw.nent.

10·phone conversation with the insured

70

Phone Cost Office Cost Picture Cost Misc. Cost

Gross Total

l O phone call to the insured to confirm apt the insured said she could not be present '

7.00 62.01

157.50

0.00

ore () G ,.,, -. , t:- · 2013

$597.59

10 phone call to the insured to eonfinn the npt. The insured snid that it would need to be on another date

10 phone conversation with the insured scheduled the apt for 12/28

120 travel discussion with tbe insured, inspection


35 label photos


0 Trevor Miles

10 call from Trevor Miles OK to make settlement offer to· the insured

10 settlement offer to the insured as authorized

10 phone conversation with Trevor Miles on offer extended to the insured

0 for $1500 as authorized on 1/19

20 closing report to carrier

415

Bill TO

00922 -dl.EC 2 ,tm~

Invoice ----------····-·--····--··

DATE INVOICE#

12/31/12 11572

SHIP TO

American Fellowship 25925 Telegraph Rd

--------··----·--···-1,--------- ---------1

Suite 200 Southfield, Michigan 48033 Attn Trevor Miles

liberty Claim Services, LLC P.O.Box 2064 Brighton, Michigan 48114 Phone No 810-599-1771

-----------······-·······--------..J


1/30/13 ----~---------------------,----'----.-----'--.-------·----········--

ITEM

Property Loss phone Insured:

office photographs

Address;

Thank you for your business I

DESCRIPTION QTY RATE AMOUNT --------l--------·-··' -·

11.08 51.50

22 2.25

570.62 3.00

99.29 49.50

----+-------'---------· ··-··-· - ·-------l Subtotal

0%Tax

Total

722.41

722.41

'-------------------·----·--·---

00922 00!'. ,.-r"\OEC .2 6 2Df Adjuster Bud O'Brien Hourly Rate ($$/hour)= 51.50 Insured - -Claimant Mileage (.42/Mile) 0 Claim No.

PolicyNo.

Date of Loss about July 18, 2006 Pictures @ 2.25/picture 22

Date 7/19/2006

7/19/2006

7/20/2006

8/2/2006

8/2/2006

8/3/2006

8/3/2006

8/7/2006

8/7/2006

8/8/2006

8/24/2006

Time (mins )Action Taken 15 reviewed file & setup

IO phone call to the iusured apt for 7/20

240 travel to loss site, inspected roof and interior

90 ptepared estimate



15 label photos

10 phone conversation with Gene lvanoff settlement authority granted

10 phone conversation with the insured settlement offer

45 prepared release, letter to the insured and note to carrier

20 correspondence to carrier with the signed settlement agreement

665

Hours to date .. _ .08 Payment 570.62 Mileage Cost 0.00 Phone Cost 3.00 Office Cost 99.29 Picture Cost 49.50 Misc. Cost 0.00

Gross Total $722.41


BILL TO


. ITEM

Property Loss mileage Insured:

Claim No:

DESCRIPTION

Dale of Loss: 12/26/2006 phone office photographs .


r C ~) o. .-,dl·,'., . (, /J f('j c',,I!, ,\

b Invoice

E .... DATE

!~31/12

SHIP TO ---------'-- --------...J


DUE DATE

1/30/13

QTY RATE

6.92

Subtotal

0%Tax

40

24

·rotaJ

51.50 0.42

2.25

P.O. NUMBER

AMOUNT

356.38 16.80

4.00 . 62.01

54.00

493.19

493.19

Adjuster

Insw-ed

Claimant

Claim No.

Policy No.

Date of Loss

Date ll/8/2006

11/8/2006

11/8/2006

11/14/2006

12/26/2006

12/26/2006

12/29/2006

12/29/2006

1/2/2007

l/8/2007

1/8/2007

1/27/2007

0( ·1:U: r. 2 0 ?.O tf Bud O'Brien Hourly Rate ($$/hour)= 51.50 Hours to date t>.92 - Payment 356.38

Mileage (.42/Mile) 40 Mileage Cost 16.80 - Phone Cost 4.00 Office Cost 62.01


00922


15 set up &review new assignment.

5 phone ca11 to the insured LTM

10 phone call from the insured set apt

175 travel to loss site, met with the insured, obtained non waiver, statement & inspected damages


120 review file in preparation of report to carrier/label photos

10 phone conversation Gene Ivanoff OK to settle as recommended



. 10 phone con versa ti on with the insurred regarding settlement

30 correspondence to the insured & prepared settlement release

20 closing repm1 to carrier

415

$493.19

Amertcan Fellowship 25925 Telegraph Rd Suite 200

BILL TO


ITEM

Property Loss Insured: Polley No:

· DESCRIPTION



b0~2?

SHIP TO

Liberty Claim Services, LLC P .O.Box 2064 Brighton, Michigan 48114 Phone No: 810-599-1771

DUE DATE

1/30/13

0

QTY RATE

6.58

Subtotal

0%Tax

60

24

Total

51.50

0.42

2.26

nrr- 2 I) '1(l'1.; l, . \r t.-11.,.l

Invoice

P.O. NUMBER

AMOUNT

338.87

25.20 4.50

58.96 64.00

481.53

481.53

--------······-····---·····---·-'---....J

Adjuster

Insured

Claimant

ClaimNo.

Po1icyNo.

Date of Loss

Date 12/1/2006

12/1/2006

12/2/2006

12/4/2006

1/6/2007

1/8/2007

1/9/2007

1/9/2007

1/9/2007

1/11/2007

1/27/2007

, ..... .,~.,)/'vi....,. l!

Bud O'Brien Hourly Rate ($$/hour)= 51.50 HourPt~~r~-, . i i5'~~\i) Payment 338.87



00922·


10 phone messages to the insul'ed

10 phone conversation with the insured apt to inspect 12/4

150 travel, met with the insured, obtalned statement & inspection


15 review report & enclosures & photos

Gross Total

10 phone convel'sation with Trevor Miles that we had S200 settlement authority after the

0 deductible.

5 phone c11tls to the insured left messages

10 phone conversation with the insured conveyed settlement offer insured would like 0 more but will settle for the S200

30 prepared correspondence to the insured with settlement release

20 closing report to carrier

395

$481.53

00822

BILL TO SHIP TO 1-------- ·----------·-·····.----···j,. __ __;__ _______ , __ ½ .. ---·-- ~-----'


Liberty Claim Services, LLC P.O.Box 2064 Brighton, Michigan 48114 Phone No: B10--599-1771

DUE DATE

1/30/13 ~~--·--·--· ..... ,-----------------~-

ITEM DESCRIPTION QTY RATE

Properly Loss l;ns;u;re~d]: iiiiiiiiiiiiiiil-------r-Policy No:

7

mileage office photographs

Date of Loss: 1 0/20/2006 40

21

51.50

0.42

2.25

P.O. NUMBER

AMOUNT

360.50

16.80 62.73 47.25

----!-----'------'---------··--·-····-·· ..... Thank you for your business! Subtotal

0%Tax

Total

4B7.28

487.28

Adjuster

Insured

Claimant

Claim No.

Policy No.

Date of Loss

Date 10/23/2006

10/23/2006

10/24/2006

10/27/2006

10/30/2006

10/30/2006

10/30/2006

11/4/2006

11/6/2006

11/16/2006

Bud O'Brien Hourly Rate ($$/hour)= 51.50 Hours t~~1 ::/BW - Payment 360.50 Mileage (.42/Mile) 40 Mileage Cost 16.80

Phone Cost 0.00 - Office Cost 62.73 10/20/2006 Pictures @2.25/picture 21 Picture Cost 47.25

Misc. Cost 0,00 ·009.22

Gross Total $487.28 Time (mins)Action Taken


. 10 phone conversation with insured set up apt

150 travel to loss site, met with the insured, obtained statement & inspected damages

10 fax document from the instired,


100 review file & prepare report to carrier

10 phone call from the insured

20 phone conversation carrier settlement aurtho1ity granted along/ commUJJicated offer to the insured

30 prepared letter and release to the insured

30 reviewed file in preparation of closing report to carrier

420

DATE

06.122·· Ut.l'I 2 o 21.\\\ nvo1ce --- ·- ··--·-~ --•-

INVOICE# ,__ __ ___, ______ .,._ ........... ~. 12/31/12 11576

··-···-··----~-··-·--·-···------------------------------~


BILL TO

Soulhfleld, Michigan 48033 Attn Trevor MIies

SHIP TO


'---------------·-·-------··--· .. ···-··· .. -.·-·······------------------'

.. ITEM DESCRIPTION



Policy No: Date of Loss : 6/3/2004

DUE DATE P.O. NUMBER ·-·~ -·--·--- ... -... -------·-· ----·-- ·-····-.-·~--.. ,. ·-- ·----·-·--

1/30/13

QTY RATE AMOUNT

5.75 51.50 296.13

40 0.42 16.80 1.50

51.53 12 2.25 27.00

-----'----······· .. ·····----·,- ..................... ····---··- -·-------1---------''-------..L.---------1 Thank you for your business! Subtotal

0%Tax

392.96

1---------·------····---·--------··-·-·-----·--·

Total 392.96

.__ ___________________ ...................... ·--·---·--.·-·-··----··---··· .. ····· .. ·-···---·--··----········-·----····-···-·-

Adjuster

Insured

Claimant

Claim No.

Policy No.

Date of Loss

Date 10/10/2006

10/11/2006

10/12/2006

10/19/2006

10/31/2006

11/6/2006

H/10/2006

Bud O'Btien Hourly Rate ($$/hour)= 51.50

Mileage (.42/Mile)

-6/3/2004 Pictures @ 2.25/picture

Time (mins)Action Taken 15 reviewed file & set up

5 phone call to the insured left phone messuge

10 plione call to the insured apt 10/19

135 travel to loss site, met with the insured, inspection



60 prepared sample denial letter at tlle request of the carrier

345

40

12

Ul>~~~·u, ... ,...:,~ r r-:-:_. "' Hours to date· ::,.75 Payment 296.13 Mileage Cost 16,80 Phone Cost 1.50 Office Cost 51.53 Picture Cost 27.00 Misc. Cost 0,00

nee S\ J ?SWJ

Gross Total $392.96


BILL TO


ITEM DESCRIPTION ·!-----··----------

Property Loss Insured:_


Policy No: Date of Loss: 11/19/2006


---·~-

00922 C .-_,.. • ..-.._. : ) ~ 0_ C -

Invoice _D_A_T_E_I----__ IN_v_oicE·#==i

_1_21_3_1_11_2--'-___ 1 _15_7~- .. ____ _]

SHIP TO

Liberty Claim Services, LLC P.O.Box 2064 Brtghlon, Michigan 48114 Phone No; 810-599-1771

···h·---·-·-··· DUE DATE P.O. NUMBER

,.--·-··--·~~~ ... ·-· 1/30/13

·-- ·--QTY RATE AMOUNT ........ , ... __ -·-~--·····-

10.25 51.50 527.88

60 0.42 25.20 2.00

91.85 75 2.25 168.75

,..,u.,••• ~ a,.,._,.~ e•

Subtotal 815.68

0% Tax -····""·-

Total 815.68

... ,-. ---·""'"····

Adjuster Bud O'Brien Hourly Rate ($$/hour)= 51.50 H ~ '-1 .• -,- ~ ~Hf.f 2 6 2 u :" ours to ate . 5 · '

Insured -- Payment 527:88 Claimant Mileage (.42/M:ile) 60 Mileage Cost 25.20 Claim No. Phone Cost 2.00 PolicyNo. - Office Cost 91.85 Date of Loss 11/19/2006 Pictures @2.25/picture 75 Picture Cost ·168,75

Misc. Cost 0,00

00922

Gross Total $815.68 Date Time (minAction Taken

11/21/2006 15 set up & review new assignment. ·

11/22/2006 10 phone conversation with the Insured set apt

11/2712006 l &5 travel to the loss site, met with the insu!'ed, secured statement, inspection

12/1/2007 140 travel to the loss site met with the insured, his contractor did not show, inspected and photograph

12/8/2006

1/7/2007

l/C)/2007

1/11/2007

1/13/2007

0 the crawl space

45 pl'epare estimate

10 advised insured that his contactor has not been cooperative

90 review in pl.'eparation of report to carrier

75 review in preparation ofreport to carrier

45 Iobel photos

615

BILL TO

..... "' "·....,

om~·~i tijtl Invoice

DATE ·1NVOlCE# -············---------1

12/31/12 11578

SHIP TO 1----···-----------------l---~ ----------

American Fellowship Liberty Claim Services, LLC 25925 Telegraph Rd P.O. Box 2064 Suite 200 Brighton, Michigan 48114 Southfield, Michigan 48033 Phone No: 810-599-1771 Attn Trevor Miles

DUE DATE

1/30/13

ITEM DESCRIPTION QTY .RATE

Property Loss



9.42

Subtotal

0%Tax

50

50

Total

51.50

0.42

2.25

P.O. NUMBER

AMOUNT

485.13

21.00 3.00

84.41 112.50

706.04

706.04

~-----------······" ...... _ ___,

OO.H22 Adjuster Bud O'Brien Hourly Rate ($$/hour)= 51.50 Houi., LU cta't~. Insured - Payment Claimant Mileage (.42/MHe) 50" Mileage Cost Claim No. Phone Cost Policy No. - Office Cost Date of Loss 2/26/2007 Pictures @ 2.25/picture 50 Picture Cost

Misc. Cost



10 phone conversation with-relative oftlle insured set apt

Date 4/12/2007

4/12/2007

4/18/2007 240 travel to the loss site. Met with- and her daughter. They were late for the apt

DEC 9, 6 7.01'.} 9.42

485.13 21.00 3.00

84.41 112.50

0.00

$706.04

0 surveyed the building condition and the repairs that had been _made. phone conversation witl1 the

0 insured regarding my assessment slated the cabinets did not require replacement

5/13/2007

5/15/2007

5/15/2007

5/16/2007

5/'2212001

120 review file in prep11ration of estimate


20 phone conversation with carrier & insured relative to the settlement authority & acceptance

30 prepared settlement release aud correspondence to the insured and carrier

10 phone call from Gene Ivanoff he indicated that the agent called the co

0 advised my opinion that the cabinets in the kitchen did not requh·e replacement and the

0 bathroom did not require remodeling from this incident.

0 advised that we had sent release to the insw-ed based on Ws settlement demand

565

BILLTO 1-.'....------ ----------··-----·---·-·


ITEM DESCRIPTION

00922 DEC 2 6 ion


12/31/12 ·11579

· SHIPTO ---------1

Liberty Claim Services, LLC P.O. BOX 2064 Brighton, Michigan 48114 Phone No: 810-599-1771

-----------·--···· ............ ·-··--·---


1/30/13

QTY RATE AMOUNT ·----------+--·-·-··---+---'------l~-------l



Claim No: Polley No: Sept 1 & Oct 21, 2006

7.92 51.50

75 0.42

37 2.25

407.88

31.50 8.50

70.97 83.25

------------··-·--·-··--------!------'-----··-· ....... ···--···----··--· Thank you for your business! Subtotal

0%Tax

602.10

1----------------·-----··-.. ------

Total 602.10

'-----------···--·----····--···----___JL._ ____________ . ___ ··-··---·-

Adjuster

Insured

Claimant

Claim No.

Policy No.

Date of Loss

Date 10/24/2006

10/24/2006

10/24/2006

10/26/2006

12/14, 2006

12/14/2006

12/21/2006

1/3/2007

l/4/2007

_ 1/4/2007

I/4/2007

1/4/2007

1/6/2007

l/6/2007

Bud01Brien Hourly Rate ($$/hour)= 51.50 Hours to lilft91;~ - Mileage (.42/Mile) --Oct 21, & September 01, 2006 Pictures @2.25/picture


10 phone conve~mtion witlt insured arranged apt


10 phone call from the insured will cancel claim

Payment 75 Mileage Cost

Phone Cost Office Cost


Gross Total

10 advised by carrier to reopen file as the insured changed mind about with drawing claim

10 phone conversation with insured arranged inspection



90 review file with report to carrier

lO phone conversation with Trevor Miles ok to offer the insured

0 223.7l 11pplying2 deductibles

15 phone conversation with the insured advised offer based on cost of

0 painting contractor not a general contractor also advised two different

0 source of the woter damages to the family mom and living room

0 ceiling so 2 deductibles insured advised that we should send

0 the settlement agreement for the 223. 71

10 phone conversation witlt Trevor Miles he received call from the insured

0 and will only apply one deductible

10 phone conversation regarding settlement release

30 prepared settlement release & letter to the insured

475

407.88

31.50 8.50

70.97 83.25

0.00

$602.10

I '


BILL TO


ITEM·

Property Loss Insured: -Policy No:

DESCRIPTION



lC',f'',~, •:, ,; "\ ('_> _: r.___ _ .. ·-•. ' ( ti ti'

DATE

12131/12

SHIP TO ----~-

Liberty Claim Services, LLC P.O.Box 2064 Brighton, Michigan 48114 Phone No; 810-599-1771

DUE DATE

1/30/13

QlY RATE·

5.42

Subtotal

0%Tax

45

47

Total

51.50

0.42

2.25

Invoice INVOICE #. ::: __ ~

11580 _]

P.O. NUMBER

AMOUNT

279.13

18.90 3.60

48.78 105.75

456.16

456.16

Adjuster Bud O'Brien Hourly Rate ($$/hour)= 51.50 Insured -Claimant Mileage (.42/Mile) 45 Claim No.

Policy No. -Date of Loss reported October 01, 2006 Pictures @ 2.25/picture 47

Date Time (mins )Action Taken 10/20/2006

10/20/2006

10/26/2006

10/30/2006

11/24/2006

11/24/2006

11/24/2006

15 reviewed file & set up

10 phone conversation with the insured inspection 10/26

10 phone conversation with the insured will need to reschedule

0 for 10/30

165 travel, inspection


15 review report & enclosures

20 label photos

32S

·\.., ..... ,:_ ~-... Hours to date 5.42 Payment 279.13 Mileage Cost 18.90 Phone Cost 3.60 Office Cost 48.78 Picture Cost 105.75 Misc. Cost 0.00

Gross Total$456.16

00922

j

I.

l . l .

BILL TO

00922Jl:C 2 6 20l3 Invoice

[ DATE

[~2131/12

INVOIC~

_ 11581=--:==:J

1----------------------i.-----------------------American Fellowship 25925 Telegraph Rd

SHIP TO

Suite 200 SoU1hfield, Michigan 48033 Attn Trevor MIies

ITEM . . DE~CRIPTIO~

Property Loss Insured:~


PollcyN~ Date of Loss October/ November 2006

--- __ ...__ ____________ ----Thank you for your business I


DUE DATE -~-·

1/30/13

QTY RATE

5.5 51.50

60 0.42

27 2.25

. ..

-·· Subtotal

D%Tax

Total ...

-· P.O. NUMBER

-

AMOUNT ...

283.25

25.20 1.00

49.29 60.75

-· --. --~ ·-419.4 9

419.4 9

'

Adjuster Bud O'Brien Hourly Rate ($$/hour)= 51.50

Insured -Claimant Mileage (.42/Mile) 60 Claim No.

PolicyNo. -Date of Loss 10 & 1 l/2006 Pictures @ 2.25/picture

Date 2/5/2007

2/5/2007

2/15/'2007

3/8/'2007

3/8/2007

Time (mins)Action Taken 15 set up & review new nssigrunent.

10 phone conversation with the insured set up apt 215 travel to the loss site, met with the insured, inspection

15 hlbeled photos

75 review fiJe in preparation of report to carrier

330

27

Hours to date Payment Mileage Cost Phone Cost

5.50

283.25

25.20

1.00 Office Cost 49.29

Picture Cost 60. 75 Misc. Cos11)E.C 2 6 20\a o.oo

Gross Total $419.49


Bill TO ·


.,

DESCRIPTION ITEM

Property loss Insured:-=-Policy No: Date of Loss: 3/5 2007


__ ... ,., .. , Thank you for your business!

.....

00922

Invoice C . -- ~- DATE INVOICE~:=i

Li~~~-11_12__._ ___ 1_1_5B_2_:~

SHIP TO

liberty Claim Services, llC P.O.Box 2064 Brighton, Michigan 48114

. Phone No: 810-599-1771

DUE DATE

1/30/13

-··

Q1Y RATE ...... ., .. u •

4,33 51.50

20 0.42

8 2.25

... Subtotal

0%Tax

Total

-··· P.O. NUMBER

AMOUNT

223,00

8.40 1.00

38.80 18.00

. ... ···-289.20

289.20

..,

Adjuster Bud O'Brien Hourly Rate ($$/hour)= · 51.50

Insured -·-Claimant Mileage (.42/Mile) 20

Claim No.

Policy No. -Date of Loss 3/5/2007 Reported Pictures @ 2,25/picture 8

Date Time (mins)Action Taken 3/7fl007

3/7fl007

3/9fl007

3/30/2007

3/30/2007

3/30/2007


10 phone conversation with insured set apt

120 travel to loss site, obtained non waiver, R/St & inspeetion

30 reviewed file in preparation of estimate


10 fabel photos

260

00922 Hours to date 4.33 Payment 223.00 Mileage Cost 8.40 Phone Cost 1.00 Office Cost 38.80 Picture Cost 18.00 Misc. Cost 0.00

Gross Total $289.20

t '

I

I _

BILL TO ___ ... ,~~------------American Fellowship 25925 Telegraph Rd Suite 200 Southfield, Michigan 48033 Attn Trevor Miles

--- ---·-·~---~-~----

ITEM· 0ESCR1PTION

SHIP TO

Liberty Claim Services, LLC P ,O.Box 2064 Brighton, Michigan 48114

- Phone No: 810-599-1771

DUE DATE

1/30/13

RATE --~ ----<----· _________ , ____ ----+- ---1-- ----

Property Loss Insured: ... Policy No:


Dale of Loss 2006/2007


4.83

Subtotal

0% Tax

60

Total

51.50

0.42

P.O. NUMBER

AMOUNT

248.75

25.20 2.00

43.28

319.23

319.23

00922 Adjuster Bud O'Brien Hourly Rate ($$/hour)= 51.50 Hours to CdtlrJ1.94,83 Insured - Payme~t , ... ,,, 248.75

w.ti-~ii ,~·egl Claimant

Claim No.

Policy No.

Date of Loss

-Date

i .

2/1/2007

~/2/2007

2/7/2007-

2/14/2007

3/7/2007

Mileage (.42/Mile)

-2006/2007 reported Pictures @2.25/picture

Time (mins)Action Taken 15 setup & review new assignment,

10 phone call to the insured

60 Phone Cost Office Cost


Gross Total

10 phone conversation witb insured since roof snow covered changed apt

165 travel to loss location met with the insured, inspection


290

25,20

2,00

43.28 0.00

0.00

$319.23

American Fellowship 25925 Telegraph Rd Sulte200

BILL·TO


12/31112

SHIP TO

liberty Claim Services, LLC P .O.Box 2064 Brighton, Michigan 48114 Phone No: 010:599.1771

Invoice INVOICE#

11584

----------w .... _____ · .... -----------~--······---··--.... --.-·-··-


1/30/13

ITEM DESCRIPTIOl'J QTY RATE- AMOUNT

Property Loss Insured; 10.33 51.50 532.00 Claim No: Policy No: Date of Loss 15/2006 & 2110/2007

mileage 76 0.42 31,92 phone 3.00 office 92.97 photographs 55 2.25 123.75

---------·-···---·. ····-----1-----L._--··-········- ·----·----·-··------! Thank you for your buslnessl Subtotal

0%Tax

783.64

1----------- . ··--·-----···- ---·--·rotal 783.64

Adjuster

Insured

Claimant

Bud O'Brien Hourly Rate ($$/hour)= 51.50

Mileage (.42/Mile) 76

Hours to date 10.33

Payment 532.00 Mileage t(Rc6sB ~J 7.(1'153 1.92

ClaimNo. - 730041 Phone Cost 3.00

PolicyNo. -Date of Loss 12/15/2006 Febrnary IO, 2007 Pictures@ 2.25/picture 55

Date 2/22/2007

2/22/2007

2/28/2007

Time (minAction Taken 15 set up & review new assignment.

5 phone messages leftfor insured

IO phone messages_ left for insured ( 4 x )

10 pltone conversation with the insured apt to inspect loss

Office Cost 92.97 Picture Cost 123.75

Misc. Cost o.oo ;_. {.~922 ·

Gross Total $783.64

3/6/2007

3/8/2007

4/14/2007

4/18/2007

4/27/2007

195 travel to loss site, met with Mrs- & also with Mr.lalll, inspection, attic, first floor & basement


4/28/2007

6/7/).007


10 phone conversation with Gene Ivanoffok on the recommend figures

0 with tlie exception of the paneling no coverage

75 prepared settleme!?-t releasse to the insured both claims

0 prepared corl'espondence to the insured

30 prepared closing report to carrier

620

I '

00922 ,:

Invoice

·"··--··--·---····--·----·· --· ·-- ·--····-----------·--·------BILL TO

,----


ITEM ·-

Property Loss Insured: __ Policy No: Claim No;-

DESCRIPTION

Date of loss: 10f612006 mlleage phone office photographs

.

··---------·---........ --.

...

...

SHIP TO ···---.. -----

Liberty Claim Services, LLC P.O.Box2064 Brighton, Michigan 48114 Phone No: 810-599-1771

... , . DUE DATE

1/4/14 "

QlY RATE ·---~~

4.83 51.50

50 0.42

5 2,25

Subtotal

0%Tax

Total ....... --~------- -····

P.O.NUMBER .....

··-AMOUNT

--248.75

21.00 2.00

19.91 11.25

---~-

302.91

-·-~- .. - ..... ~--,·-· ...... ~---·

302.91

Adjuster

Insured

Claimant

ClaimNo.

Policy No.

Bud O'Brien

-Date of Loss . . 10/6/2006

- .£

Hourly Rate ($$/hour)= 51.50

Mileage (.42&1:ile) 50

Pictures @ 2.25/picture

Date Time (mins) Action Taken 10/17/2006

10/17/2006

10/26/2006

10/30/2006

11/4/2006

11/10/2006

15 set up & review new assignment

10 phone conversation with the insured; set appt

10 phone conversation with the insured; rescheduled appt

165 travel, inspection


60 prepared report to canier

290

Hours to date 4.83

Payment 248.75

Mileage Cost 21.00

Phone Cost 2.00

Office Cost 19.91

Picture Cost 11.25

Misc. Cost 0.00

Gross Total $302.91

:· 0922

DATE

2/9/09

/Ji.:.C U -0 2013,

·· -·~ Invoice INVOICE#

11373/2

-------··-············ ······---------------------------, BILL TO SHIP TO 1------------·--···. --······· ············-·-·-···---------1,,-----------------------1

American Fellowship 26001 Telegraph Rd Southfield, Michigan 48034 Attn Netcy Handy & Gene Ivanoff

Liberty Claim Services, LLC TAXID-Phone No: 810-599-1771 P.O.BOX 2064 Brighton, Michigan 48114

L....-_________________ ...___ ___ ·-······· .. •·••••• .. ··-······-··········-·······-··············-"-··-·-·


2119/09 ------.----- -····-·-· ···-··············--·--·····---·····------.---~--.-----~--r----------1

ITEM DESCRIPTION


mileage phone office parking

Dale of Loss Oclber 6, 2006 Policy No: Claim No:

QTY RATE

16.5 51.50

100 0.42

----.L.._---------------··· d -·· ••••••••••• - ....................... -·-······

Thank you for your business! Subtotal

0%Tax

Total

AMOUNT

849.75

42.00 8.00

118.97 10.00

1,028.72

1,028.72

American Fellowship 25925 Telegraph Rd SUile 200

BILL TO


J )ZZ llEC 2 6 2013

Invoice DATE

12/5113

I SHIP TO

liberty Claim Services, LLC ' P .O.Box 2064 j' Brighton, Michigan 46114 j Phone No: 810-599--1771

INVOICE#

11591

_______________ .,__ _______ , .. ,_ .............. ________ __J

ITEM

Colleclion Fees Filing Fees milage phone/postage labor

'--·-

DESCRIPTION

...........

DUE DATE

1/4114

QTY RATE ·--··

120 0.42

g 60.00

Subtotal

0¾Tax

Total . ,., ...

P.O. NUMBER

. -· ··"'···-· A MOUNT

-··"-·---

190.00 50.40

7.56 540.00

787.96

787.96

DEC 2 G 2Dll Adj"l1ster Bud O'Brien Hourly Ra_te ($$/hour)= 51. 5 0 Insured - Hours to date 16.50

Payment $849.75

$42.00 $8.00

$118.97

$0.00

$10.00

Claimant

Claim No.

Policy No. -Mileage (.42/Mile) 100 Mileage Cost

Phone Cost Office Cost

Date of Los~ or about I 0/5/06 [email protected]/picture 0 Picture Cost

Date 3/12/2008

3/20/2008

3/20/2008

3/24/2008

3/25/2008

3/25/2008

3/26/2008

3/26/2008

3/26/2008

3/26/2008

3/28/2008

7/21/2008

7/21/2008

perking Misc. Cost

0922 , \.I").I""\, • -


60 revh:wed file for deposition

210 travel to atty Shirey's office met with atty, reviewed file for deposition

30 phone convel'sation with atty Rogg re deposition

90 review file in preparation of depostion

105 l'eview file in preparation ofdepostion

10 phone call from atty Shirey's office pint atty wants to start at noon instead of 1 PM

5 phone call to Jeff Rogg

10 phone conversation with Jeff Rogg re the change in depo time

10 phone conversation with atty Shirey's office

10 phone conversation with atty Shirey

420 travei met with atty Shirey & Rogg, deposition

15 phone call to ERS collection entity

15 phone call from Gene Ivanoff advised that I did not auth01·lz:e repairs by ERS

0 ofMt'S. Fulle1Js property. I also did not make initial contact with ERS as to the

0 advised tllat ERS sent me a bill that I nor Liberty claim service initially contacted

0 ERS nol' did AmedcanFellowship

990

$1,028.72

E X ''•'"'•' ''•'"• ,·

H I B I T

2

};'A:M£rucAN FELLOWSHIP

, April 14, 2016

MUTUAL INSlJRANCE COMP ANY 30600 TELEGRAPH ROAD, SUITE 1260, BJNGJIA.MFAR.lv!S, MI 48015

PHONE (248) 352- 7500 I FAX (248) 593 -8119

Liberty Claim Services LLC POBox2064 Brighton, MI 48114

' '

RE: American Fellowship - Proof of Claim# 00921 : · · Liberty Claim Services LLC - Received December 26, 2013

Dear Agent:

Section 500,8142 (1) of the Michigan Insurance Code states as follows: "Except as provided in subsection (2), the priority of _distribution of claims from the insurer's estate shall be in accordance with the order in which each class of claims is set forth in this section, Every claim in each class shall be paid in full or adequate funds retained for their payment before the members of the next class receive J?ayment."

The above proof of claim has been classified as a Class 5 claim as defined by Section 500,8142 of the Micbig;m Insurance Code.

Unfortunately, American Fellowsbip'Mutual will have inmmieient assets to pay creditors past Class 2 priority level, Therefon;, this lette.r is to inform you that Lib','fty Claim Services LLC will not be receiving any distributions from the proceeds of the American Fellowship Mutual liquidation estate, ·

Yours truly,

/~-:- ~ James Gerber Deputy Liquidator American F ellowshlp Mutual in Liquidatj,on

E X

'' .• , ,,~ .. ·.· '" ',<..

H I B I T

3

LIBERTY CLAIM SERVICES LLC P.O. BOX 2064

BRIGHTON, MICHIGAN 48114 ph 810-599-1771

[email protected]

Via Registered & Regular Mail May 13, 2016

Mr. James Gerber American Fellowship Mutual Insurance 30600 Telegraph Road Suite 1260 Bingham Farms, Michigan 48025

Re: American Fellowship-Proof of Claim No : 00922-00921 Service Invoices Bud O'Brien I Liberty Claim Services

Dear Mr. Gerber:

The purpose of this correspondence is to acknowledge the following: our phone conversation of April 21, 2016, your letters dated Aprll 14, 2016 and to confirm my disputation of the Classification 5 which you have registered relative to my service invoices, i.e. my agreed upon wages and the incurred expenses for the Claim Service work performed by the undersign during the provisional employment by American Fellowship Mutual Insurance Company.

This correspondence also supplements my earlier Proof of Claim response. For approximately 10 years there has been a continuous Dual Employment relationship by me with American Fellowship as coordinated with Angus McDonald and Roger Dennis. American Fellowship Mutual Insurance Company a license Insurance entity to sell Property and Casualty Insurance in the State of Michigan and compelled to the Rules, Laws and Standards set forth in the Insurance

Re: 00921 and 00922

Code of 1956 along with the supplement amendments, the NAIC Uniform Trade Practice Act, the Fair Labor Standard Act, the Statutory and Common Laws of Trusts, the Contracts of Insurance and any other applicable Laws.

MAY 1 6 20lS

American Fellowship Mutual Directors and Officers were aware that I was functioning as a License Property and Casualty Claims Adjuster and Appraiser in disputed matters and would exclusively provide them with Claim Adjusting experience , so forthwith an Express Agreement was reached that I would be paid an hourly wage and incurred expenses under an implied Provisional Dual Employment Agreement. The undersigned on each and every Claim Assignment and Appraisal Appointment received did performed the directed and requested Claims handling function and activity providing American Fellowship Associates / Management with preliminary, interim, and dosing reporting on each and every assignment. At no time over the 10 year period did American Fellowship Mutual Insurance Associates, Management, Directors or Officers object to my services or negate my wages or the request for reimbursement of expenses.

For compliance of the Insurance Code of 1956, its amendments, the NAIC Uniform Trade Practice Act and each individual Policyholder Contract American Fellowship used my claim expertise and knowledge to fulfill their promise to timely investigate, settle and pay each and every claim upon which coverage required indemnification or exclusionary exception.

Although the undersigned provided American Fellowship Mutual with Individual Claims handling on specified policyholder claims including the requested investigations, policyholder facts and surrounding information, including the

. MAY 1 G 2016 Page 3 Re: 00921 and 00922

assessment of damages and settlement negotiations and Appraiser Appointments of Disputed matters the undersign has not received any advance payment or any · compensation, for my wages and incurred expenses for the years 2006, 2007 and 2008 which total $49,679.51 contrary to the Express Agreement.

Under the various Doctrines , statutory Laws, Common Laws, Insurance Codes, Trade Practices Act, Trust Agreements, Express Contractual Agreements, Beneficiary Laws, Equitable Lien Laws, Equitable Assignment Laws, applicable Policyholder language specific to the assign claims and the Fair Standard Labor Laws my wages and expenses for work performed have not been received nor paid by anyone and yet I have and have had a proprietary claim for compensation for labor that l performed for American Fellowship and its policyholders, and an Assignment of Loss Adjusting Expense funds to be held in Trust by American Fellowship and its egregious and unfair to peel down the insolvency of American Fellowship and ignore my proprietary and superior claim to all other entities or individuals making claim against the assets part of which had been assigned to me under a Trust Agreement and allow for those funds to be commingled with American Fellowship Assets.

Failure to recognize my Proprietary claim unjustly enriches American Fellowship and wrongfully compensates other entities or individuals making claim against the assets of the Liquidation of American Fellowship.

The majority of my claim for employment services provided to American Fellowship and its policyholders are for wages. I was offered $23,000.00 in January 2013 and I felt it was unfair as no one has compensated me for the labor that I put

MAY 16 2016 Page 4 Re : 00921 and 00922

forth in fulfilling American Fellowship's legal obligation to its policyholders. I felt the offer was unconscionable, unjust enrichment by American Fellowship and unfair that my proprietary claim was not recognized.

There was dialogue and communications with the American Fellowship Rehabilitator although no alternative offer even though l agreed to reduce my wage claim several times. Not hearing from the Rehabilitator to my written suggestion of March 20, 2013 to a mutually agreeable alternative dispute forum to resolve my claim and I did attempt to reach the Rehabilitator via phone on June 11, 2013, however, I did not hear back from the Rehabilitator until June 12, 2013 upon which time I was told that the court had just signed an order to Liquidate American Fellowship. Had we spoken on June 11, 2013, I am sure we would have reached agreement to resolve my claim as to a forum or settlement amount.

On April 21, 2016 I had a phone conversation with the Liquidator/Rehabilitator relative to the notice that I received indicating that I was going to be considered a General Creditor in Classification 5 and because of the insolvency of the Insurer he stated there would only be funds to pay the first and second Classifications which according to the Liquidator's assessment I would receive("0) compensation/consideration. The Liquidator indicates that if I want to dispute the Classification I need to provide him with a written response stating forth the reason or reasons for my objects. Additionally I had asked for the documentation relative to the claim which I requested is filed under American Fellowship's Directors

UAY 16 20!6

Page 5 Re : 00921 and 00922

and Officers policy along with the financial documents which demonstrates the financial condition of American Fellowship and the time periods involved. I wait to receive the requested information from the Liquidator/ Rehabilitator.

This will confirm my objection to the Classification ( 5 ) which you have recorded as to my wages and expenses.

I have a Proprietary Claim as I was functioning as positional Dual Capacity employee for American Fellowship for specific cases regarding my wages, travel and incidental expenses. American Fellowship Mutual Insurance Directors and Officers including but not limited to Angus McDonald, Roger Dennis, Tom Pardo, Netzy Handy, Trevor Miles, and Gene Ivanoff that I would work exclusively on their policyholder claims as directed, therefore I was considered a provisional employee.

The following basis provides persuasive proof that I should receive proprietary and superior consideration of my wages and expenses before and above all the other Claim Classifications which claim indebtedness.

My reasons for disputing the 5 Classification is as follows:

A. l have an Equitable Lien and Constructive Trust based on the Express Contract that for my service work that I would be paid an hourly rate coupled with the travel and incidental printing and copy services. There were prior year service billings which were paid by the Carrier which supports the agreement. There is an unjust enrichment of the Insurer of not paying the agreed upon wages and expenses which should be prevented with my Statutory Lien under The Equitable Lien Doctrine.

Re: 00921 and 00922

B. I have an Equitable Assignment of the Loss Adjusting Expense Reserves which were established on each of the Claim Cases that I worked on.

Under the Insurance Code of 1956 and the NAIC Uniform Trade Practice Act the Insurer is required to establish Indemnity and Loss Adjusting Expense reserves on each of their policyholder claims.

The Loss Adjusting Expense Reserves on the cases that I had worked on were to be a funds held as a Constructive Trust as my wages and expenses. When my work product was submitted and the Loss Adjusting Reserves were established there was an Equitable Assignment of those Loss Adjusting Expenses with conversion to a Constructive Trust in my behalf. Even though these funds had not yet transfer the funds are to satisfy my Equitable Assignment, whereas, the Funds American Fellowship has held and required to be held under the Insurance Code of Michigan 1956, NAIC UTPA and the Trusts Laws are to be set aside for me.

MAY 16 2016

If the Funds under the Equitable Assignment, Equitable Lien and Trusts were not set aside for the work/service, wages and expenses that I preformed and incurred their commingling of the specific Loss Adjusting Expense Funds into their general funds should be considered conversion and or unauthorized use of the Funds to be held in trust for me. The Insurance Code Regulatory Language provides obligations and performance requirements of the Insurer. Performance of the Insurance Code Requirements by Third Parties suggest the pledging of the Loss Adjustment

Re: 00921 and 00922

Expenses to the Third Party without physically releasing the funds, so there is a gap in the transfer or a Constructive Trust created.

C. The Policyholder contract requires certain Conditions and Obligations of the Insured and the Insurer, which would include the payment of covered claims and expenses for the handling of the Claim or the resolution of a disputed claim through the Appraisal Process. Additionally The Insurance Code of 1956 and the NAIC Uniform Trade Practice Act requires the Insurance Carrier to fulfill the Promise made under the insurance policy that is to investigate, settle and pay a covered and compensatory claim within a fair, reasonable and timely manner. As a Third Party I Provisional Employee performing the required contract obligation of the Insurer, I become a Third Party Beneficiary of the policy wherein the Insurer indicates that it will pay to investigate and settle the claim. The Insurance Carrier's utilization of a Third Party/ Provisional Employee to perform a part of the Insurer's obligations does not abrogate or nullify their obligations under the contract and the Promises made to the Policyholder to provide and include for payment the Loss Adjusting Expense Funds to the Third Party/Provisional Employee performing the functions. It suggest when the insurer attempts to avoid payment of the Loss Adjusting Expense funds by way of an individuals/Third Party /Provisional Employee wages, they are in violation of the policy provisions, the Insurance Code and the NAJC Uniform Trade Practice Act, Fair Labor Standard Act, Trusts Laws

D. The Insurance Carrier is in violation of the Fair Labor Standards Act through the misclassification of my

' MAY 16 2016

Re: 00921 and 00922

employment status, whereas in a Dual Employment Capacity I am considered a positional employee. I am in a proprietary Classification and should receive compensation for my wages and expenses before and superior to others in the Liquidation Classification. To do otherwise is unjustly. The Insurer involved in the payment of my employment fees has other employees including Full Time all of whom have been paid their wages. It is unfair and discriminatory to exclude my Classification as a Proprietary and Superior Recipient of Funds as a Provisional Employee, Equitable Lien, Equitable Trust, Constructive Trust, Trusts, Equitable Assignments, Equitable Rights, Restitution Rights, and Third Party Beneficiary Rights with respect to wages and incidental expenses that the Carrier contracted with me. When accepting the positional employment on a Case Assignment, I never received any correspondence written or otherwise that I would not be considered a Positional Employee on a Case Assignment basis. During the 10 years of employment, I never receive a 1099 from the Insurance Carrier.

E. The Doctrine of Restitution Rights should require the Insurance Carrier to satisfy my wages and expenses incurred at their direction proprletarily and superior to other Classifications, whereas, my wages and expenses identified under the Loss Adjusting Expense Reserve under each policyholder handled case assignment as required under the Insurance Code of 1956 and the NAIC Uniform Trade Practice Act were Funds earmarked for me as wages and expenses, were to be held by American Fellowship under a Trusts/Constructive Trusts arrangement. If these Loss Adjustment Funds earmarked as a Trusts/Constructive Trusts to be held for me on the handled case assignment were commingled by American Fellowship

Re : 00921 and 00922

or others with their General Funds this then suggest conversion and an unauthorized use of funds or unethical enrichment by the Insurance carrier, thus required payment to me under the Rights of Restitution.

F. There is a breach of Fiduciary obligations, negligent misrepresentation and unconscionable conduct against the Directors, Officers and other key Associates

MAY 16 2016

who failed to preserve the Loss Adjusting Expense funds, which were entrusted under a Trust/Constructive Trust, to them in exchange of payment for my service wages and requested incurred expenses. Their negligent and or intentional conduct allowing the peeling away of the solvency of the company prior to and after the submission of my work product, wages and expenses and before the liquidation has inflicted emotional harm, distress and hardship. It is unconscionable and inequitable that the Insurance Carrier and its Liquidator should ignore my Proprietary Classification · and retain the benefit of my entrusted wages and expenses free of any legal obligation for the remuneration of other Creditors.

l pray that the Liquidated/Rehabilitator after further review will recognize the equitable relief which I have pointed out and will immediately elevate my claim for payment of my wages and expenses to a Proprietary Claim superior and before all other Classifications involved in this Liquidation.

In the alternative I am asking that the court will authorize relief in payment of my wages and expenses as a Proprietary and Superior level to all other Claim Classifications, including but not limited to all other costs and remedies available under the laws as the court determines

Re:00921 and00922

Respectfully submitted and thank you in advance of your extended courtesy.

ly~

B / Br:en Liberty Claim Services, LLC

MAY 1 6 2016

E X H I B

e . •

I T

4

fone 21, 2016

AMERICAN FELLOWSHIP MUTUAL INSURANCE COMPANY 30600 TELEGRAPH,ROAD, SWTE 1260, BINGHAM FARMS, MI 48015

PH01vE (248) 352 - 7500 I FAX (248) 593-8119

Liberty Claim Services LLC Attn: Bud O'Brien POBox2064 Brighton, MI 48114

RE: Americrur Fellowship - Proofs of Claim #00921 and #00922 · Liberty C!!lllll Services LLC ~ Received Decemner 26, 2013

Tltjs is to advise you that the Liquidator has reviewed your proofs of claim filed on December 26, 2013 .in the total amount of $49,679.51. After review, the Liquidator has adjudicated your proofs of cl!lllll in the allowed amount of $33,547.60. As communicated to you previously, the balance of your claim is time-barred by the applicable' 6-year statute. of limitations and is therefore denied.

You were further advised by letter dated April 14, 2016 that the allowed amo11pt of your claim has been classified as a general creditor cl!lllll, which is accorded Class 5 distribution priority from the assets of American Fellowship's liquidation estate under Section 8142(l)(e) of the Michigan Insurance Code, MCL 500.8142(1)(e): My legal counsel and I have reviewed your letter dated May 13, 2016 disputing the Class 5 priority assigned to your claim. However, there is no evidence supporting your contention that you were an American Fellowship employee, rather than a third-party contractor providing independent claim.~ adjusting services to American .Fellowship. For example, you have provided no employment 6ontracts, W-2s, employersponsored bene:fi~ plans, or other documentation suggestive of your claimed status as an employee, nor is there any such documentation in American Fellowship's records. Conversely, your proofs of claim were submitted in the name of and included invoices directing payment to Liberty Claim Services LLC, your May 13, 2016 Jetter was on Liberty Claim Services letterhead, and you are on file with .fue State of Michigan as the sole organizer, sole member/owner, and resident. agent of your .independent company "Liberty Claims Service, L.L. C." This. evidence overwhelmingly establishes that y0u provided claims adjusting services to American Fellowship through your independent company as a third-party contractOJ' or ve'ndor, not as an employee. Consequently, MCL 500.8142(l)(e) classifies your cl!lllll for payment ofthese services and any related expenses, to the extent they are allowed and are not time-barred, as a Class 5 general creditor cl!lllll. This letter reaffu::ms the Class 5 priority classification of the allowed portion of your claim, and your request to change that classificatiqn is .denied.

In addition, please note that even if you had established that your claim involved services peiforrned as an American Fel,lowship employee, it would still be classified as a Class 5 cl!lllll.

7015 0640 DODD 3132 1399

'· ',.

MCL 500.8142(1 )(a) and (d) prov:ide that claims for services performed by American Fellowship employees may receive Class 1 or Class 4 priority, but only up to $1,000 and if certain conditions are met. . One condition for this elevated priority is that the employee's services must have been performed "within 1 year 'before the filing of', the liquidation petition. The American Fellowship liquidation petition was filed on June 4, 2013, so any employee services potentially · eligible for Class l or Class 4 priority must have been performed by June 4, 2012. Admittedly, none ofthe·services underlying your claim were provided on or after June 4, 2012. In fact, the last service you provided was in 2008, nearly four years before the cut-of!'. Accordingly, your claim would not be eligible for Class l or Class 4 priority even if you established that you were an American FeHowship employet,, and would remain a Class 5 general creditor claim.

Section 500.8142(1) of the Michigan Insurance Code; MCL 500.8142(1), states as follows: . ''Except as pro,~ded in subsection (2), fue priority of distribution of claims from the insurer's estate shall be in accordance with the order in which each class of claims is set forth in this secfion. Every claim in each class shall be paid in full or adequate fuuds retained for their .payment before the members of the next class receive payment."

·As· you were previously advised, American Fellowship will not have sufficient assets tci pay creditors past the Class 2 priority level. Therefore, this letter again infonns you and confirms that the allowed portion of Liberty Claim. Services LLC's claim, in the amount of $33,547.60, \Vil! not be receiving any distributions from the assets of American Fellowship's liquidation estate.

In accordance with Section 500.8139(1) of the Michigan Insurance Code, MCL 500.8139(1 ), this letter serves as your formal notice of the Liquidator's claim determination. You have sixty (60) from the date this letter was mailed to file written objections to this dete!;Jl1irucion. Any

· objections should be mailed to:

American Fellowship in Liquidation 30600 Telegraph Road Suite 1260 Bingham Farms, 'MI 48025-5725

Yours truly, ~-~~~ James Gerber

· Deputy Liquidator , American Fello'WS!rip Mutual Iusurance Company ii1 Liquidation

E X H I B I T

5

LIBERTY CLAIM SERVICES LLC P.O. BOX 2064

BRIGHTON, MlCI-IIGAN 48114 Ph 810-599-1771

[email protected] Via Registered & Regular Mail

August 16, 2016

Mr. James Gerber American Felfowship Mutual Insurance 30600 Telegraph Road Suite 1260 Bingham Farms, Mlchigan 48025

Re: American Fellowship-Proof of Clalm No: 00922-00921 Service Invoices Bud O'Brien / Liberty Claim Services

Dear Mr. Gerber:

The purpose of this correspondence is to acknowledge and respond to your June 21, 2016 correspondence, continue my request for the documents/records, which you had promised to forward relative to our April 14, 2016 phone conversation, continue my requests for payment of my wages and expenses based on the bi.lateral contractual employment service agreement, restate the legal basis of my proprietary superior claim to all other classifications involved in this Liquidation and moreover because of your refusal to elevate and pay my wage and expenses superior and before all other Classifications, I am looking for the scheduled court hearing date that you had promised to arrange with the court relative to the various disagreements with respect to your interpretation of my wages and expenses claim superior and before all other Classifications.

A. In your first paragraph you have arbitrarily reduced my wages and expense reimbursement because of a statute of

Re: 00921 and 00922

limitations defense. As I previously stated there has been a continued service arrangement with American Fellowship Mutual Insurance Company through February 9, 2009. Under the Doctrine of Continual Representation the Statute of Limitations was tolled and did not begin to accrue until that date, therefore all wages and expenses have been submitted within the Statute of Limitations.

B. In your second paragraph you have again ignored my statement of my employment arrangements initiated with Mr. Roger Dennis and Mr. Angus McDonald in 1998. As a sole individual, which you mentioned I was hired exclusively to service and handle the American Fellowship Mutual Claims as a positional, temporary and leased worker/employee. I believe your further search will identify the interpretation that I have had a legal right to expect payment of wages and expenses from (AFMIC) American Fellowship Mutual Insurance Company as a positional, temporary and leased worker/employee.

You initially acknowledge receipt of my request for wages on or about Octobe.r 2012. I explained to you some of the reasons why the delay; because of my wife's health coupled with two auto accident I took some time off relative to the American Fellowship Mutual Services, whereas the only matter outstanding was limited to my service wages and incurred expenses. All other activity on each and every assignment for AFIC was concluded to completion. When I realized that I would be unable to submit an itemized service and expense time sheet with the agreed upon hourly wage, I did have a conversation with AFMIC full time associates alerting them to the fact.

Believe me had my spouse been in better health my wages . and expense time sheets based on my employment

Re: 00921 and 00922

arrangements with AFMIC would have been submitted much sooner.

Your refusal to pay my wages and expenses demonstrates improper employment practices on the part of AFMIC and as to your rehabilitation capacity. I feel that I was in a protective category relative to age and the need to attend to my family under the FMLA. To ignore my status, I believe is in violation of the Federal Fair Labor Standard Act or other applicable laws, which I previously addressed in earlier correspondence.

Under my employment arrangements with AFMIC we were both mutually aware that AFMC had an obligation to its policyholders to comply with the Code of 1956 along with the supplement amendments, the NAIC Uniform Trade Practice Act, the statutory and Common Laws of Trusts, the Contracts of Insurance and any other applicable Laws. My employment arrangements was to work jointly with the other AFMIC employees and its policyholders as well as all other required parties in the service of their claims, i.e. investigations, reporting, communications, evaluations, negotiations, and settlement of specified claims. Under each and every policyholder' § contract, which I serviced for the principal AFMIC as their agent it provides me a Third Party Beneficiary Claim, which is statutorily superior to all other Classifications.

When there is a breach of the implied covenant of good faith and fair dealing by AFMIC without any payment of my wages and expenses incurred, as required under the statute and each contract of insurance policyholder serviced, it suggests Bad Faith and Un-Fair Dealings.

Re: 00921 and 00922

As part of my claim which you have refused to honor as promised by AFMIC (wages and expenses of $49,679.51), additionally I will request that the court will grant 10% compounded penalty interest per year as required under the Statute and consequential damages, which the court deems is appropriate as it has been approximately 8 years since I provide the agreed upon services to AFMIC, its policyholders and third party claimants.

I believe that it will not square well with the court the "notion of good sense and fair dealings for the risk of loss to be born by the party promised to be paid."

Your correspondence did not address each and every legal basis that l had referenced, relative to my proprietary superior claim of wages and expenses as to all other Classifications, so your specific lack of response indicates your admission of my claims under the various Doctrines, Statutory Laws, Common Laws, Insurance Codes, Trade Practices Act, Trust Agreements, Express Contractual Agreements, Beneficiary Laws, Equitable Lien Laws, Equitable Assignment Laws, applicable Policyholder language specific to the assign claims and the Fair Standard Labor Laws and all other applicable laws to include but not limited to: a. breach of contract, b. implied in fact contract, c. doctrine of consideration, d. age and FMLA discrimination, employment law, e. third party beneficiary status under each and every contract serviced, f. law of restitution doctrine as a result of unjustified enrichment by AFMIC retaining the Loss Adjusting Expenses rather than held in an escrow account in payment of my wages and expenses,

Re: 00921 and 00922

g. constructive trust negligence, h. bad faith; failing to deal in good faith and fair dealings relative to their financial circumstances as to my services wages and expense payment, i. quasi contract, j. quantum meruit k. equitable lien and assignment, j. doctrine of continued representation,

I also await the previously requested documentation:

a. the denial letter or letters you stated you had relative to the claim which I requested filed under AFMIC Directors, and Officers policy, General Liability Policy, Employment Liability Policy, Personal Liability and Advertising Liability policy, other applicable policies,

b. furnish a copy of the AFMIC polides; c. the financial documents which demonstrates the

financial condition of Amerfcan Fellowship and the time periods involved,

d. a list of any and all entities and individuals making claim and their Classification,

Failure to recognize my Proprietary claim unjustly enriches AFMIC and wrongfully compensates other entities or individuals making claim against the assets of the Liquidation of AFMIC.

It's egregious and unfair to peel down the insolvency of AFMIC and ignore my proprietary and superior claims to all other entities, individuals or classifications.

Re: 00921 and 00922

Respectfully submitted and thank you in advance of your extended courtesy.

SJ, .cere~ly ' . ;f/:;v?;;k'.- fc0 Ii ud O' rien

Liberty Claim Services, LLC

E X H I B .. .,. , .. '" ...

I T

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STATE OF MICHIGAN CIRCUIT COURT FOR THE 30TH JUDICIAL CIRCUIT

INGHAM COUNTY

R. KEVIN CLINTON, COMMISSIONER OF THE OFFICE OF FINANCIAL AND INSURANCE REGULATION,

Petitioner,

V

AMERICAN FELLOWSHIP 11:UTUAL INSURANCE COMPANY,

Respondent.

Christopher L. Kerr (P57131) M. Elizabeth Lippitt (P70373) Assistant Attorneys General Attorneys for Petitioner Corporate Oversight Division P. 0. Box 30755 Lansing, MI 48909 (517) 373-1160

I

Case No. 12-1173-CR

HON. WILLIAM E. COLLETTE

[IN LIQUIDATION]

ORDER. GRANTING PETITION AND GOVERNINQ PROCEDURES FOR COURT ADJ!JDICATIO_N OF

CLAIMS DETERMINATION DISPUTE

At a session of said Court held in the Circuit Courtrooms

for the County of Ingham, State of Michigan, on the __ day of May, 2018.

PRESENT: HONORABLE WILLIAM E. COLLETTE, CIRCUIT COURT JUDGE

1

WHEREAS, Patrick M. McPharlin, Director of the Michigan Department of

Insurance and Financial Services and duly appointed Liquidator of American

Fellowship Mutual Insurance Company (the "Liquidator"),1 has filed a Petition for

Court Adjudication of Claims Determination Dispute (the "Petition"); and

WHEREAS, MCL 500.8139 governs the process for resolving disputes

involving the Liquidator's denial of a claim filed in this ongoing liquidation

proceeding of American Fellowship Mutual Insurance Company ("American

Fellowship"); and

WHEREAS, MCL 500.8139(2) provides that if a claimant files objections

with the Liquidator and the Liquidator does not alter his denial of the claim as a

result of those objections, the Liquidator shall ask the Court to adjudicate the

claims determination dispute; and

WHEREAS, as described in the Petition, there is an unresolved dispute

requiring this Court's review and adjudication that has been raised by claimant

Liberty Claim Services, LLC ("Liberty") through its owner, Lester "Bud'' O'Brien

("Mr. O'Brien"), regarding Liberty's two Proofs of Claim filed in this liquidation

proceeding and the determinations on those claims made by the Liquidator and his

appointed Special Deputy Liquidator James Gerber (the "Deputy Liquidator"); and

1 Pursuant to Executive Order No. 2013-1 effective March 18, 2013, the Michigan Office of Financial and Insurance Regulation ("0 FIR'') was renamed the l\.1ichigan Department of Insurance and Financial Services ("DIFS") and all the authority, powers, duties, functions, and responsibilities of the former Commissioner ofOFIR were transferred to the newly-created position of the Director of DIFS. Governor Snyder duly appointed Patrick M. McPharlin as the Director of DIFS effective May 18, 2015, making him the Liquidator of American Fellowship as of that date.

2

\VHEREAS, the Court agrees with the Liquidator's assessment, as set forth

in the Petition, that because this dispute involves legal questions of statutory

interpretation and no genuine issues of material fact, it is capable of decision on

written motion(s) for summary disposition under MCR 2.116(0)(8) and (10); and

VVHEREAS, the Court therefore finds it appropriate for the Court's orderly,

thorough, and fair adjudication of this claims determination dispute, as well as in

the interest of judicial economy, to set a schedule for briefing and oral argument

and to establish certain other procedures governing the Court's adjudication of this

dispute;

NOW, 'rHEREFORE, IT IS HEREBY ORDERED that the Court GRANTS

the Liquidator's Petition, and the Court will adjudicate the unresolved claims

determination dispute raised by claimant Liberty through its owner, Mr. O'Brien,

as described more fully in the Petition and the Exhibits attached thereto.

IT IS FURTHER ORDERED that the Court's adjudication of this claims

determination dispute is governed by the following procedures:

1) Liberty's two Proofs of Claim attached as Exhibit 1 to the Petition are considered filed with and submitted to the Court for its determination as to whether: (a) these claims should be allowed or denied, in whole or in part; and (b) to the extent they are allowed, their distribution priority from the assets of American Fellowship's liquidation estate.

2) The Michigan Property and Casualty Guaranty Association ("MPCGA") has standing and may fully participate in this dispute involving Liberty's Proofs of Claim. The MPCGA is American Fellowship's largest creditor and is statutorily obligated to pay American Fellowship policyholder claims that meet the requirements for a "covered claim" and are otherwise subject to payment under the MPCGA's governing statutes, MCL 500.7901 500.7949.

3

3) The Liquidator, Liberty, and MPCGA (ifit decides to participate) will submit briefs to the Court regarding whether the Liquidator and Deputy Liquidator: (a) correctly adjudicated Liberty's Proofs of Claim in the allowed amount of $33,547.60; and (b) correctly classified Liberty's Proofs of Claim as having Class 5 (general creditor) distribution priority under MCL 500.8142(l)(e). The parties' briefs will be submitted according to the following briefing schedule:

• Brieff\ of t!J.e Liquidator an!i MPCO:A (if it decides to participate): Due 35 calendar days after entry of this Order.

• Brief oJ Libertv/Mr. O'Brien: Due 35 calendar days after service of the Liquidator's Brief.

• Reply Briefs of the Liquidator and MPCGA (if it decides to participate): May be filed at the party's option; if filed, reply briefs are due 14 calendar days after service of Liberty/Mr. O'Brien's Brief and are limited to 5 pages.

4) Following completion of the foregoing briefing schedule, the Court will schedule oral argument on this claims determination dispute at an available date and time not earlier than 7 days after the last brief is filed.

ITIS SO ORDERED.

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Honorable "William E. Collette Circuit Court Judge

state of michigan circuit court for the 30th judicial ... · 30/05/2018 · priority under mcl...

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