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UNDERWOOD, WILSON, BERRY, STEIN & JOHNSON, P.C.
A PROFESSIONAL CORPORATION
ATTORNEYS AND COUNSELORS AT LAW
December 23, 1991
Mr. Donald Lynn Thompson
Mrs. Gloria Thompson
Wellington Manor Apartments
2700 S.W. 16th, Apt. #174
Amarillo, TX 79102Re: Allstate Insurance Company Policy No. 216719784
Dear Mr. and Mrs. Thompson:
This law firm represents Allstate Insurance Company with regard to your claim under Policy No. 216719784. With respect to the reported fire which allegedly occurred on or about November 26, 1991, we wish to advise you that Allstate Insurance Company has been made aware of evidence that indicates that the fire at 4005 Northeast 17th may have been intentionally set rather than accidental.
Under the Policy you are required, among other things, to submit to an examination under oath and subscribe or sign a record of that examination and produce all pertinent records for Allstate's examination as may be reasonably required at such reasonable time and place as may be designated by Allstate or its representative and to permit copies thereof to be made. Until a determination has been made as to whether the loss is covered, we must insist that you follow the express terms of the Policy and that you comply with all requirements placed on you by the Policy.
Allstate Insurance Company hereby requests that each of you submit to an examination under oath at the offices of Underwood, Wilson, Berry, Stein & Johnson, P.C., 1500 Amarillo National Bank Building, Amarillo, Texas on Thursday, January 9, 1992 with Gloria Thompson's examination beginning at 9:30 a.m. and Donald Thompson's examination to begin at l:00 p.m. We request that you produce all pertinent records for examination at that time, including but not limited to your 1989 and 1990 tax returns, financial statements, any mortgages or liens on the property, and copies of all payments made in the past year. If this time is not convenient for you, please contact me so that we may reschedule the examination under oath.
While Allstate Insurance Company is willing to proceed with the investigation of this reported loss, they will only do so on the condition that their actions in doing so will not prejudice any rights or defenses they currently have, have had in the past, or may have in the future under Policy No. 216719784 or under any applicable law, regardless of whether such rights or defenses have been specifically referred to in this letter. By expressly reserving our client's rights to deny coverage under the Policy, at some later date, none of their actions in investigating or proceeding further shall be construed in any way as waiving or creating an estoppel of their rights under the Policy.
Neither our actions nor the actions of Allstate shall be deemed in any way to be an admission of liability of coverage under said Policy. Allstate Insurance Company expressly reserves its rights to institute, at any time after receipt of this letter, an action to have the rights of the parties determined. You may wish to discuss this matter with your own personal attorney.
If you have any questions, comments, or objections concerning Allstate's position as outlined in this letter or would like to schedule your examinations at a different time, please feel free to contact me.
Very truly yours,
____________________
D. Lynn TateDLT/dd; 0348-223
cc: Mr. Bob Wilson
Allstate Insurance Company
Claim No. 216719784
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