84f18X2818

8854288984 PAGE 82f87

 

I, being duly sworn, do hereby depose and state the following:

1. I am presentllears old and reside ix-

2. I worked for OST, Inc. in connection with the Federal Emergency
Management Agency?s Hurricane Sandy Claims Review process
from approximately 4-20-2015 to 3-24-2016.

3. My job title while employed in connection with the SCR was Case Manager, and
my primary responsibilities included communicating with the policyholder to discuss
all aspects of their Sandy claim including but not limited to explaining process,
determining primary concerns, obtaining information and documentation regarding
damages and cost of repairs as completed to date, renewing original file including
estimates and/or supplements as directed by FEMA and reviewing
recommendations once approved by FEMA with the policyholders and their options.
4. I have approximately 15 years? experience evaluating and adjusting residential
property damage in connection with insurance claims. I have adjusted approximately
6,000 of claims during that time.

5. My quali?cations for my work on the SCR included FEMA ?ood certi?cation
for residential, commercial, mobil homes and RCBAP. I have worked all types of
?ooding cents including major events over a 15 year period involving large losses
and total destruction of covered properties.

6. I did not adjust claims on behalf of Write Your Own insurers

in connection with Hurricane Sandy before my employment in connection with the SCR.

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7. I reviewed approximately 80-90 ?ood insurance claims during my employment
on the SCR
3. While revieWing claims for the SCH, I received instructions ?'om my superiors at

DST and from FEMA managers of the SCR to exclude ii-om my paymen



recommendations items that should have been covered under Standard Flood

Insurance Policies 
9. While reviewing claims for the SCR, I also received instructions

comprehensive evaluation of claims assigned to me in order to identify 

not to conduct a

aoh item of

property damage subject to insurance coverage, but rather was told to use software

developed for the BER by McKinscy 8: Company C?Mcansey?) that 

iduced a range of

expected values for each claim based on the preperty?s square footage and approximate

qualify of construction. I was directed to tailor my evaluation to fall within this range

even if I identified additional damage that warranted insurance coverage.

10.

If I submitted a recommendation for payment on a claim that exceeded the range

generated by the threshold software, my supervisor and FEMA would not

approve it and direct me to revise my ?ndings.

11.

Other reviewers received these same instructions, which re?ected

the 

general Operating procedure. The express purpose of these instructions was to limit the

payments made on each claim that I reviewed.
12-

evaluating ?ood insurance claim damage-

Many other reviewers working for the BER lacked signi?cant experience

 

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13. Other reviewers working for the SCR had worked for WYO insurers adjusting
Hurricane Sandy claims before working for the SCR.

14. I left the SCR because I believe that it was not reviewing claims in accordance
with a0cepted industry procedures or the requirements. Rather, it was an elaborate
process designed to justify mininml payments to policyholders irrespective of the actual
merits of their claims.

I declare under penalty of perjury that the information contained in this affidavit is true

and correct to the best of my current knowledge and belief.