8854288984 PAGE 85f87

FFE #3

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

1. I am old and reside 

2. I worked for CST, 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, reviewing original ?le including estimates and
supplements, preparing revised estimates and/or supplements as directed by FEMA and

reviewing recommendations once approved by FEMA with the policyholders and options

4. I have approximately 26 years? experience evaluating and adjusting residential
property darnagc in connection with insurance claims. I have adjusted approximately
10,400 of claims during that time. 

5. My quali?cations for my work on the SCR included FEMA ?ood certi?cation for
residential, commercial, mobile home and RCBAP. I have worked all types of ?ooding
events including major events over a 26 year period involving large loses and total

destruction of covered property.

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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.

7. renewed approximately 60 ?ood insurance clairns during my employment on
the SCR.
8. While reviewing claims for the SCR, I received instructions ?'ona my superiors at

DST and ??om FEMA managers of the SCH. to euclude from my payment

recommendations items that should have been covered under Standard Flood

Insurance Policies 

9. While reviewing claims for the SCR. I also received instructions not to conduct a

comprehensive evaluation of claims assigned to me in order to identify

property damage subject to insurance coverage, but rather was told to 11:

developed for the SCR by McKinsey do Company (?McKinsey?) that pr

each item of
ac software

odneed a range of

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

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

even if I identi?ed additional damage that warranted insurance coverage.

ll).

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

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

approve it and direct me to mvise my ?ndings.

11.

general operating procedure. The express purpose of these instructions

payments made on each claim that I reviewed.

Other reviewers received these same instructions, which re?ected the 

was to limit the

 

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8854288984 PAGE 

12. Many other reviewers working for the SCR lacked signi?cant experience
evaluating ?ood insurance claim damage.

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

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

I declare under penalty of perjury that the information contained in this af?davit is true

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