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APPENDIX C <br />Meredith, Weinstein & Numbers, LLP <br />x+tntnayt it LTW <br />MW.'rdstruz <br />Lemur, Calitzrris en <br />TtMptem (415) 927-W2O F=XMIG (415) 92"-$2'—M <br />April 11, 2013 <br />is rIail and USPS <br />Gap/ J. Valeriano <br />Ander�3nn, AAcPhartin & Conners, LLP <br />4-1A Svuih Flower Street; 31St Floor <br />Los Angeles, CA 90071-290 <br />EmO. gjjvgAmdaw-com <br />Re: San Mateo CoLtnty M nsq uilo and Vector Contnal District Errlpigyee TheP <br />Hadford Claim No- 11392634 <br />Your File No,, 0022-638 <br />Dear Mr. Valerians: <br />This vAl rarpQnd prelifnjnarily to your letter dated March 5. 2013, in which you <br />advise that HarUbrd has denied coverage In thla maMr. The District h� bathiswprtc-d <br />and orlendi!d tha. atfte-r dragging this =fter on for nevriy two years, Halfford has <br />chozers to avoid its r--sponsQ1,jjjUes by denying covemga lbr 11he very mis-conduct tha; <br />Hartford agmead to insure, under policies for which Hortford received at Gust 6 years of <br />premium! HaWkord's 'invasUgation' of this ctarr, inGfuding repeated requests for the <br />earns information it had already received, plainly demonstrates that Hartford has sT)annt <br />considerable resources looking for %vays to avoid honemg its abligatioris, rather thal <br />assisti� its insured in raspondjng to 'Uhis catastraPhic 10M I will not revieW tha <br />chronology of eventr. 4, this leiter, but the cormpandence over the pist two years <br />speaks for i4self. <br />The District firna1v reported discovery of the scheme tnvoMng Senney and <br />Sinipsta in June of 201 i. There is no dispute that the 1051's is a covered loss under <br />Section AA.A of the Hartford policy. Seeney and Sinipata were "e3 nplQyU,68" who <br />embe=- led rn,,onev "m the Distnict. causinog a ciwered loss <br />Hart ord asser� that if the District had JOoked into SEartay's background p6of 10 <br />h1nng her it would have cis cavared her efiHnal past. However, whether or not this is <br />true, itis irrelevant There was no requirernent that the District check for Past criminal <br />activity. In fpct SecUon C of the application asks several quesilons rabout whether the <br />Dist(fct conducted pry employment background checks, and the District answened 'W <br />to each of them. Acoordingly, the DistncVs failure to conduct background chadks does <br />not supe art a denial of the claire, and Hartford's rad noo to background checks <br />demornatrates Hietford's attempt to manufacture reasons fiat its denial. <br />15 <br />ZZ abed - 'TVJ <br />