oregonoregoncasualtyadjusters.org/articles/ocaa news may 2019.pdfvista forensics! we trust he made...

Exciting News: Our nextmonthly luncheon is Tuesday,

May 14, 2019 at 11:30am at thePortland Spaghetti Factory – FREEPARKING 0715 SW Bancroft.Bring a guest – win a gift card!

Please register ahead for the lunch-eon and make your food selection. If you forget toregister, don’t let that stop you from attending asyou can register when you check in. Come onecome all! Bring a friend! To RSVP go to:www.oregoncasualtyadjusters.org/ocaarsvp.html.

Remember to read your newsletter!

We had a great turn out for our annual OCAA Sym-posium last month at the Wilsonville Holiday Inn.The committee worked diligently in putting thisevent together and I want to thank each and everyone of you! Thank you Roger Howson for takingthe helm and lining up the speakers and for hostingas our MC. A personal shout-out to all of our sym-posium speakers for taking the time to prepare, pre-sent and educate us. This year’s $1,000 sponsors(pictured at right) were Davis Rothwell Earle &Xochihua (DREX), CRDN and EDT, and our mealsponsors were Thenell Law Group and EFI Global— thank you also to all our other sponsors and ven-

(See President’s Message… continued on page 3)

www.oregoncasualtyadjusters.orgPO Box 87 • Dexter, OR 97431

Founded in 1935OCAA provides

Insurance Claim Professionalswith information,

educational resources,and an arena for networking

Claims

Adjusters

Association

OregonMAY 2019

Message from OCAA President

Nancy Greenidge, Norcross

Go to www.oregoncasualtyadjusters.org/calendar.html

Friday, July 128:00am Shotgun StartStone Creek Golf Club

~ See page 21 for registration form ~

Thank you CRDN, DREX & EDT!Spring Symposium Core Sponsors

OCAA — M ay 2019OCAA — M ay 2019 - 2 -

This newsletter is a publication of the Oregon Claims Adjusters AssociationIt is produced and distributed monthly by

Alquemie Publishing Ink(541) 937-2611

Mail correspondence to:PO Box 87, Dexter, Oregon 97431

Email to: [email protected] or [email protected]

OCAA Vital Statistics 2018-19PO Box 87, Dexter, OR 97431Website: www.oregoncasualtyadjusters.orgEmail: [email protected]

BOWLINGCAROL [email protected]

BUDGET & FINANCE COMMITTEEJUDY DAUFEL, 503/266-9603CONSTITUTION & BYLAWSPAST PRES. SPUNKY GRAY, 800/788-3933PAST PRES. RON GRAY, 855/426-8898GOLFJUDY DAUFEL, 503/266-9603LIZ DUNNING, 503/969-0054HOLIDAY PARTYPOSITION OPEN

LEGISLATIVE LIAISONPAST PRES. SPUNKY GRAY, 800/788-3933MEMBERSHIPPOSITION OPEN

MEETING PROGRAM & SPEAKERSMELODY EWERS, 971/245-1066NEWSLETTER, SYMPOSIUM & WEBSITECOORDINATOR, EMPLOYMENT, FACEBOOKBARB TYLER, ALQUEMIE PUBLISHING541/937-2611, [email protected]

PARLIMENTARIANPAST PRES. RON GRAY, 855/426-8898SCHOLARSHIPBRIAN BEAUDRY, 503/323-2575SYMPOSIUMNANCY GREENIDGE, 503/724-8213JUDY DAUFEL, 503/266-9603

FAIR USE NOTICE: This publication contains copyrighted material the use of which has not alwaysbeen specifically authorized by the copyright owner. News and informational articles posted here are for

the non-profit purposes of education and news reporting. We believe this constitutes a 'fair use' of anysuch copyrighted material as provided for in 17 U.S.C § 107.

PRESIDENTNANCY GREENIDGENORCROSS503/[email protected]

PRESIDENT-ELECTPOSITION OPEN

TREASURERJUDY DAUFELNORCROSS503/[email protected]

SECRETARYBRIAN BEAUDRYAIG503/[email protected]

ASSOCIATE BOARD MEMBERMELODY EWERSBAKER TILLY971/[email protected]

IMMEDIATE PAST PRESIDENTJUDY DAUFELNORCROSS503/[email protected]

ASSOCIATE BOARD MEMBERJOHN BACHOFNERJORDAN RAMIS PC360/[email protected]

Standing Committees

Time11:30am to 1:00pm

LocationOld Spaghetti Factory715 SW Bancroft St, PDX

Menu Choices $15Spaghetti w/Meat Sauce, Spinach/Cheese Ravioli or Chicken CaesarSalad.

Checks, cash or credit card accepted

RSVP Requestedwww.oregoncasualtyadjusters.org

Who will takehome the

Money Pot?YOU MUST BE

PRESENT TO WIN!

At each monthly meetingsomeone could be

a lucky winner!Will you be present

to win at the next meeting?

$100 up for grabs!

No winner in April...

Crying CornerMary Luttrell, Michael Gatewood,Jeri Gilstrap, Glenn Rennemann,Lloyd Dykes were not present towin the pot!

Featured Luncheon Presenter/Topic:

“Water, water everywhere...and not onegood photo of the failure” presented by

Jeffrey Marksthaler, PE of Jensen Hughes

Next OCAA Meeting

May 14, 2019

Project Owl Wi-Fi Networkfor Natural DisasterConnections Wins IBM-Backed ContestBy Olivia CarvilleReprinted from www.insurancejournal.com

dors. We had two new vendors this year — FireCause Analysis and Gayla Dawson from Legal Lan-guage. The Registration bags were donated againby Temporary Accommodations and name badgelanyards were from Norcross McLarens. Thank youDREX for the $250 gift card to McMenamins, a giftbasket from OME, and choice wine from CharterConstruction. We could not have had such an awe-some event without you all, and of course we wel-come you all back next year.

John Bachofner rode off on the bright yellow bicy-cle donated for the Passport Prize — thank you En-vista Forensics! We trust he made it home safely!

President’s Message… (Continued from front page)

- 3 -

From a cramped living room in Brooklyn, NewYork, a handful of young computer nerds has de-veloped a new way to use technology to help savelives in natural disasters.

They have designed tiny electronic nodes insidebaseball-sized rubber casings that create a specialWi-Fi network spanning more than 100 squaremiles that can be used to connect victims and firstresponders. It’s a simple and relatively cheap con-cept, but during a natural disaster when cell towerstopple, technology fails and entire communities fallinto darkness – communication can be the differ-ence between life and death.

May Meeting PresentationJoin us for lunch May 14 and the following presen-tation by Jeffrey Marksthaler, PE, OperationsManager, Sr. Metallurgical/Materials Engineer withJensen Hughes…..

Water, water everywhere!“…and not one good photo of the failure! It goeswithout saying that scene documentation can makeor break a cause investigation. But it happens fartoo often that photo sets are missing key evidencethat get changed as soon as remediation starts. Weare frequently sent a “job-in-a-box,” together withhundreds of scene photos, but missing what we needto firmly represent the interests of the people whohired us. This presentation briefly shares guidancethat is given to us – our burden of scene documenta-tion and evidence management for robust causeanalysis.”

Ty Prichard was the actual winner of the bike buthe traded it for a TV John had won.

We also held our Past Presidents appreciation din-ner directly after the symposium where we recog-nized those who held leadership positions in thepast and those in office presently. It was a greattime of story-telling, musical entertainment, foodand fun. Thank you, Joe Sysavath and Trevor Ar-nold, for the beautiful flower arrangements for ourtables. They were amazing!

We need Vendors and Sponsors and players for ourannual golf tournament “Caddyshack”! We willreturn to Stone Creek in Oregon City on July 12with an 8:00am shotgun and afternoon luncheonwith raffle prizes. Get your teams together and reg-istered asap. We can even match you up with somefolks – don’t miss this exciting event! You don’thave to be a professional golfer – come and havesome fun!

Let’s continue to work together, mentor and shareour knowledge with others. You are a vital part inmaking OCAA a success. We need you and thankyou for helping to build up our membership!

Hope to see you all at our next meeting May 14,11:30am, at the Portland Spaghetti Factory!

lquemie ublishing

nk

Barb Tyler(541) 937∙2611

[email protected] Box 87, Dexter, Oregon 97431

Newsletter Publishing • Executive Assistance • Event PlanningAnything your volunteers need help with ~ I can assist!

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The five young men met competing against eachother at computer hackathons. They joined togetherto compete in a contest sponsored by InternationalBusiness Machines Corp. last year called Call forCode, which asked developers to use cloud, artifi-cial intelligence and other technologies to amplifypreparedness for natural disasters. Their entry, Pro-ject Owl, which stands for Organization, Where-abouts, and Logistics, uses a “clusterduck” networkmade of hubs that resemble rubber ducks, which canfloat in flooded areas. Once deployed, civilians areable to get on their cellphone to connect with firstresponders. Emergency workers are also able tolearn about weather and get information data ana-lytics through the cloud.

The team won the competition, beating more than2,500 global entries, for a $200,000 grand prize. InMarch, they joined representatives from IBM to de-ploy the devices, known as DuckLinks, across fiveregions in Puerto Rico that were devastated by Hur-ricane Maria in 2017.

“In the worst disasters, chaos and misinformationare pervasive,” said Bryan Knouse, 28, chief execu-tive officer and co-founder of Project Owl. “Withbetter information and better analytics, you can getthe resources you need to the places that need itmost.” Other members of the team include CharlieEvans, 32, Nick Feuer, 25, Taraqur Rahman, 27,and Magus Pereira, 23.

During the two-week pilot program, Project Owlattached DuckLinks with Velcro to trees in the jun-gle, perched them atop of sand dunes on beaches,stuck them on car doors and cliff faces and evenfloated them above buildings in helium balloons.Project Owl managed to create a live internet net-work across one square mile using 23 DuckLinks,communicating via the system in areas without cellreception.

Once the devices are connected, an emergency Wi-Fi network appears on smartphones directing usersto a portal where they can send messages to firstresponders and civil defense teams. The glue of thenetwork is the Papa Duck, which is a cloud softwareservice connected to all the DuckLinks. The PapaDuck offers a bird’s-eye view of the number of ci-vilians accessing the emergency portal and whatthey urgently need.

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Project Owl hopes to have enough tests done tomake their network ready in a small capacity forhurricane season on the U.S. East Coast, which be-gins in July. Every second seems to count.

Since 2000, more than 2.5 billion people have beendirectly affected by a natural disaster, with the eco-nomic impact in the trillions of dollars. Combined,2017 and 2018 were the costliest years for weather-related disasters on record, with total losses of $653billion, according to a recent analysis from U.K.insurance company Aon Plc.

“My hope is that we are able to set up internet net-works quickly at a low cost and that they work,”Knouse said. “It doesn’t have to be fancy, crazymilitary technology; part of what makes a solutionprofound is being simple and creative.”

Greg Hauser, a communications branch managerfor North Carolina Emergency Management, wasresponsible for getting the major networks back upand running after Hurricane Florence battered theCarolinas last September, killing 53 people and cut-ting power to almost two million. In order to restoreconnection, wireless carriers shifted portable towersinto the counties that lost service. But in some casesthis process took as long as 20 hours – leavingemergency responders offline and in the dark dur-ing the most critical rescue period.

“If Project Owl could generate some type of net-work connectivity and generate it out of equipmentthey drop from the sky – that would be a game-changer for us,” Hauser said.

The Weather Company, owned by IBM, predictsseven hurricanes will strike in 2019, with the poten-tial for three to be major events. While the ProjectOwl pilot program proved the system could work,the team knows it has a long way to go.

OCAA — M ay 2019OCAA — M ay 2019

The five young men met competing against eachother at computer hackathons. They joined togetherto compete in a contest sponsored by InternationalBusiness Machines Corp. last year called Call forCode, which asked developers to use cloud, artifi-cial intelligence and other technologies to amplifypreparedness for natural disasters. Their entry, Pro-ject Owl, which stands for Organization, Where-abouts, and Logistics, uses a “clusterduck” networkmade of hubs that resemble rubber ducks, which canfloat in flooded areas. Once deployed, civilians areable to get on their cellphone to connect with firstresponders. Emergency workers are also able tolearn about weather and get information data ana-lytics through the cloud.

The team won the competition, beating more than2,500 global entries, for a $200,000 grand prize. InMarch, they joined representatives from IBM to de-ploy the devices, known as DuckLinks, across fiveregions in Puerto Rico that were devastated by Hur-ricane Maria in 2017.

“In the worst disasters, chaos and misinformationare pervasive,” said Bryan Knouse, 28, chief execu-tive officer and co-founder of Project Owl. “Withbetter information and better analytics, you can getthe resources you need to the places that need itmost.” Other members of the team include CharlieEvans, 32, Nick Feuer, 25, Taraqur Rahman, 27,and Magus Pereira, 23.

During the two-week pilot program, Project Owlattached DuckLinks with Velcro to trees in the jun-gle, perched them atop of sand dunes on beaches,stuck them on car doors and cliff faces and evenfloated them above buildings in helium balloons.Project Owl managed to create a live internet net-work across one square mile using 23 DuckLinks,communicating via the system in areas without cellreception.

Once the devices are connected, an emergency Wi-Fi network appears on smartphones directing usersto a portal where they can send messages to firstresponders and civil defense teams. The glue of thenetwork is the Papa Duck, which is a cloud softwareservice connected to all the DuckLinks. The PapaDuck offers a bird’s-eye view of the number of ci-vilians accessing the emergency portal and whatthey urgently need.

- 5 -

Project Owl hopes to have enough tests done tomake their network ready in a small capacity forhurricane season on the U.S. East Coast, which be-gins in July. Every second seems to count.

Since 2000, more than 2.5 billion people have beendirectly affected by a natural disaster, with the eco-nomic impact in the trillions of dollars. Combined,2017 and 2018 were the costliest years for weather-related disasters on record, with total losses of $653billion, according to a recent analysis from U.K.insurance company Aon Plc.

“My hope is that we are able to set up internet net-works quickly at a low cost and that they work,”Knouse said. “It doesn’t have to be fancy, crazymilitary technology; part of what makes a solutionprofound is being simple and creative.”

Greg Hauser, a communications branch managerfor North Carolina Emergency Management, wasresponsible for getting the major networks back upand running after Hurricane Florence battered theCarolinas last September, killing 53 people and cut-ting power to almost two million. In order to restoreconnection, wireless carriers shifted portable towersinto the counties that lost service. But in some casesthis process took as long as 20 hours – leavingemergency responders offline and in the dark dur-ing the most critical rescue period.

“If Project Owl could generate some type of net-work connectivity and generate it out of equipmentthey drop from the sky – that would be a game-changer for us,” Hauser said.

The Weather Company, owned by IBM, predictsseven hurricanes will strike in 2019, with the poten-tial for three to be major events. While the ProjectOwl pilot program proved the system could work,the team knows it has a long way to go.


flaws in the design of these devices that can preventthem from notifying homeowners about problems orperforming other security functions.”

“Essentially, the devices are designed with the as-sumption that wireless connectivity is secure andwon’t be disrupted – which isn’t always the case,”says Bradley Reaves, co-author of the paper and anassistant professor of computer science at NorthCarolina State. “However, we have identified poten-tial solutions that can address these vulnerabilities.”

Specifically, the researchers have found that if thirdparties can hack a home’s router – or already knowthe password – they can upload network layer sup-pression malware to the router. The malware allowsdevices to upload their “heartbeat” signals, signify-ing that they are online and functional – but it blockssignals related to security, such as when a motionsensor is activated. These suppression attacks can bedone on-site or remotely.

“One reason these attacks are so problematic is thatthe system is telling homeowners that everything isOK, regardless of what’s actually happening in thehome,” Enck says.

Get a Friend orCo-Worker to JoinOCAA Today!We extend membership toanyone involved in theresolution of an insuranceclaim! Go to: www.oregoncasualtyadjusters.org

- 7 -

NEWSfrom

Around the Web

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These network layer suppression attacks are pos-sible because, for many IoT devices, it’s easy todistinguish heartbeat signals from other signals.And addressing that design feature may point theway toward a solution.

“One potential fix would be to make heartbeatsignals indistinguishable from other signals, somalware couldn’t selectively allow heartbeat sig-nals to pass through,” says TJ O’Connor, firstauthor of the paper and a graduate student atNorth Carolina State.

“Another approach would be to include more in-formation in the heartbeat signal,” O’Connorsays. “For example, if a device sends three mo-tion-sensor alerts, the subsequent heartbeat signalwould include data noting that three sensor alertshad been sent. Even if the network layer suppres-sion malware blocked the sensor alert signals, thesystem would see the heartbeat signal and knowthat three sensor alerts were sent but not received.This could then trigger a system warning forhomeowners.”

“No system is going to be perfect, but given the

Project Owl is still very much in the traditionalstart-up phase, Knouse said. The company’s head-quarters are currently in his living room in Brook-lyn, with a bench to solder the DuckLinks togetherset up beside the couch. “Calling it a living roomwould be embellishing the truth,” Knouse said.“It’s really a factory floor.”

They hope to one day connect an area up to 100square miles or more, but for now are aiming for 10square miles. The next deployment is planned laterthis month, with DuckLinks being velcroed to treesin a national park in Houston.

Flaws in Smart Home Devices May Mean FalseSense of SecurityReprinted from www.insurancejournal.com

Researchers at North Carolina State University haveidentified design flaws in “smart home” Internet-of-Things devices that allow third parties to preventdevices from sharing information. The flaws can beused to prevent security systems from signaling thatthere has been a break-in or uploading video of in-truders.

“IoT devices are becoming increasingly common,and there’s an expectation that they can contributeto our safety and security,” says William Enck, co-author of a paper on the discovery and an associateprofessor of computer science at North CarolinaState. “But we’ve found that there are widespread

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widespread adoption of IoT devices, we think it’simportant to raise awareness of countermeasuresthat device designers can use to reduce their expo-sure to attacks,” Enck says.

The paper, “Blinded and Confused: UncoveringSystemic Flaws in Device Telemetry for Smart-Home Internet of Things,” will be presented at the12th ACM Conference on Security and Privacy inWireless and Mobile Networks being held May 15-17 in Miami, Fla.

— Source: North Carolina State University

9 Guilty So Far in Massive WashingtonFraud CaseReprinted from www.insurancejournal.com

Nine people have pleaded guilty in a massive caseof fraud in Washington in which the participantssmashed cars into each other and committed otherstaged accidents in four western states to collectmore than $6 million from insurance companies.

The nine include prominent Spokane real estate de-veloper Ron Wells, who pleaded guilty in federal

court this week to numerous charges related to a2016 car crash.

Wells admitted to mail fraud, conspiracy to commitmail and wire fraud and illegal monetary transac-tions. Each offense carries between 10 and 20 yearsof jail time.

Well also agreed to pay $179,000 in restitution.

The case involves 22 defendants accused of deliber-ately staging a series of automobile, boating, stairfall, pedestrian/vehicle and other accidents inWashington, Idaho, Nevada and California from2013 to 2018.

Busy Wildfire Season Along West CoastBy Nicholas K. GeraniosReprinted from www.insurancejournal.com

Most of the country can expect a normal wildfireseason but residents along the West Coast of theUnited States should be ready for another busy sea-son, the National Interagency Fire Center said thisweek.

California experienced its deadliest and largest

OCAA — M ay 2019OCAA — M ay 2019 - 9 -

widespread adoption of IoT devices, we think it’simportant to raise awareness of countermeasuresthat device designers can use to reduce their expo-sure to attacks,” Enck says.

The paper, “Blinded and Confused: UncoveringSystemic Flaws in Device Telemetry for Smart-Home Internet of Things,” will be presented at the12th ACM Conference on Security and Privacy inWireless and Mobile Networks being held May 15-17 in Miami, Fla.

— Source: North Carolina State University

9 Guilty So Far in Massive WashingtonFraud CaseReprinted from www.insurancejournal.com

Nine people have pleaded guilty in a massive caseof fraud in Washington in which the participantssmashed cars into each other and committed otherstaged accidents in four western states to collectmore than $6 million from insurance companies.

The nine include prominent Spokane real estate de-veloper Ron Wells, who pleaded guilty in federal

court this week to numerous charges related to a2016 car crash.

Wells admitted to mail fraud, conspiracy to commitmail and wire fraud and illegal monetary transac-tions. Each offense carries between 10 and 20 yearsof jail time.

Well also agreed to pay $179,000 in restitution.

The case involves 22 defendants accused of deliber-ately staging a series of automobile, boating, stairfall, pedestrian/vehicle and other accidents inWashington, Idaho, Nevada and California from2013 to 2018.

Busy Wildfire Season Along West CoastBy Nicholas K. GeraniosReprinted from www.insurancejournal.com

Most of the country can expect a normal wildfireseason but residents along the West Coast of theUnited States should be ready for another busy sea-son, the National Interagency Fire Center said thisweek.

California experienced its deadliest and largest

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wildfires in the past two years, including a fire inthe northern part of the state last year that destroyedthe town of Paradise, killing more than 80 people. Itwas the nation’s worst death toll from a wildfire ina century.

The Boise, Idaho-based center said a heavy crop ofgrasses and fine fuels has developed across Califor-nia and should elevate fire potential as it driesthrough the summer

The terms “normal” or “above normal” refer to aformula that involves drought, precipitation andfuel conditions in each region, projected on a 10-year average, said Jennifer Smith of the fire center.

The Pacific Northwest has entered a period of mod-erate drought, which could mean an early fire sea-son in the Cascade Range and the Okanogan region.The potential for significant wildfires is above nor-mal west of the Cascade crest in Washington andOregon through August, the report said.

Some high-elevation portions of the Great Basinand the central Rocky Mountains could experiencebelow-normal wildfire potential, the agency said. Italso said that below average fire activity continuedin April across the nation, thanks to moist condi-tions from the winter.

“Precipitation received was above average acrossthe northwestern quarter of the nation and across amajority of the east,” the agency said.

While the wildfire season might be delayed inhigher, timbered elevations of the Northwest be-cause of a slower melt of the snowpack, “an excep-tion to this could be along the Canadian border inWashington, Idaho and western Montana,” theagency said. That’s because those areas have a be-low-average snowpack and are suffering from mod-erate drought.

“These areas can expect an average start to the sea-son with a potential for above normal activity,” theagency said.

In the southwest, below normal fire potential wasexpected across northern Arizona, northern NewMexico and west Texas in May and June, the reportsaid. Above normal fire potential was expected insouthern Arizona in those months.

OCAA — M ay 2019OCAA — M ay 2019 - 11 -

wildfires in the past two years, including a fire inthe northern part of the state last year that destroyedthe town of Paradise, killing more than 80 people. Itwas the nation’s worst death toll from a wildfire ina century.

The Boise, Idaho-based center said a heavy crop ofgrasses and fine fuels has developed across Califor-nia and should elevate fire potential as it driesthrough the summer

The terms “normal” or “above normal” refer to aformula that involves drought, precipitation andfuel conditions in each region, projected on a 10-year average, said Jennifer Smith of the fire center.

The Pacific Northwest has entered a period of mod-erate drought, which could mean an early fire sea-son in the Cascade Range and the Okanogan region.The potential for significant wildfires is above nor-mal west of the Cascade crest in Washington andOregon through August, the report said.

Some high-elevation portions of the Great Basinand the central Rocky Mountains could experiencebelow-normal wildfire potential, the agency said. Italso said that below average fire activity continuedin April across the nation, thanks to moist condi-tions from the winter.

“Precipitation received was above average acrossthe northwestern quarter of the nation and across amajority of the east,” the agency said.

While the wildfire season might be delayed inhigher, timbered elevations of the Northwest be-cause of a slower melt of the snowpack, “an excep-tion to this could be along the Canadian border inWashington, Idaho and western Montana,” theagency said. That’s because those areas have a be-low-average snowpack and are suffering from mod-erate drought.

“These areas can expect an average start to the sea-son with a potential for above normal activity,” theagency said.

In the southwest, below normal fire potential wasexpected across northern Arizona, northern NewMexico and west Texas in May and June, the reportsaid. Above normal fire potential was expected insouthern Arizona in those months.

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Winning ‘unwinnable’auto claimsBy Marie IgnozziReprinted from www.propertycasualty360.com

SupportOCAA

Be a Board Memberor Join a Committee!

When defending auto accident claims, not every-thing is as clear as it might seem…

Car accidents happen every single day in Amer-ica. Bodily injury claims frequently arise fromthese types of accidental injuries. When a disputeresults from such a claim, lawsuits for personal in-jury are often filed against the driver who purport-edly caused the incident.

When a claimant files a lawsuit for personal injury,the plaintiff must prove four elements to establishnegligence:

1) the defendant owed the plaintiff a duty;

2) the defendant breached that duty;

3) the defendant’s breach caused the incident; and

4) the plaintiff suffered damages as a result of thatbreach.

To recover damages, the plaintiff must prove eachof these four elements by a preponderance of theevidence. In other words, if the claimant fails toprove duty, breach, causation or damages, then theplaintiff cannot prevail at trial and the defendantwill win.

Although car accidents occur in all sorts of ways,rear-end collisions and improper left turns are oftenthe basis for those lawsuits as every driver has aduty to follow other cars at a safe distance and toyield to oncoming traffic ahead. The reason for thisis to ensure that drivers can avoid an accident iftraffic ahead should slow or come to a stop. Thisalso means a driver cannot turn left at an intersec-tion unless it is clear and only when there are suffi-cient time and distance between the driver and on-coming traffic.

Plaintiff’s lawyers love when clients have a bodilyinjury claim arising from these types of car acci-dents because, in their view, fault lies with the otherdriver and liability is clear. They see these cases asbeing a “slam dunk” in which they only have toprove the plaintiff was injured, and don’t believethat they need to prove the remaining elements to

OCAA — M ay 2019OCAA — M ay 2019 - 13 -

Winning ‘unwinnable’auto claimsBy Marie IgnozziReprinted from www.propertycasualty360.com

SupportOCAA

Be a Board Memberor Join a Committee!

When defending auto accident claims, not every-thing is as clear as it might seem…

Car accidents happen every single day in Amer-ica. Bodily injury claims frequently arise fromthese types of accidental injuries. When a disputeresults from such a claim, lawsuits for personal in-jury are often filed against the driver who purport-edly caused the incident.

When a claimant files a lawsuit for personal injury,the plaintiff must prove four elements to establishnegligence:

1) the defendant owed the plaintiff a duty;

2) the defendant breached that duty;

3) the defendant’s breach caused the incident; and

4) the plaintiff suffered damages as a result of thatbreach.

To recover damages, the plaintiff must prove eachof these four elements by a preponderance of theevidence. In other words, if the claimant fails toprove duty, breach, causation or damages, then theplaintiff cannot prevail at trial and the defendantwill win.

Although car accidents occur in all sorts of ways,rear-end collisions and improper left turns are oftenthe basis for those lawsuits as every driver has aduty to follow other cars at a safe distance and toyield to oncoming traffic ahead. The reason for thisis to ensure that drivers can avoid an accident iftraffic ahead should slow or come to a stop. Thisalso means a driver cannot turn left at an intersec-tion unless it is clear and only when there are suffi-cient time and distance between the driver and on-coming traffic.

Plaintiff’s lawyers love when clients have a bodilyinjury claim arising from these types of car acci-dents because, in their view, fault lies with the otherdriver and liability is clear. They see these cases asbeing a “slam dunk” in which they only have toprove the plaintiff was injured, and don’t believethat they need to prove the remaining elements to

meet their burden of proof in a claim for negli-gence. Indeed, plaintiff’s lawyers often file for sum-mary judgment on the issue of liability because theymistakenly don’t suspect that the defendant caneven generate a factual dispute on the issue of fault.

Determining fault

However, fault for the accident does not automati-cally equate to liability in a negligence action, andthere are circumstances that warrant a defense to alawsuit arising from a car accident. Consider thefollowing scenarios the next time you are facedwith bodily injury claim caused by a car accident toallow you to potentially win an “unwinnable” case:

Sudden, unanticipated emergency. A “suddenemergency” is created when a driver is unexpect-edly placed in a position of peril that he did not cre-ate on his own. When that occurs, the defendant’sconduct is judged based on whether it was reason-able under the circumstances.

Consider a car moving at a high rate of speed thatsuddenly comes into the defendant’s lane, forcingthe defendant to swerve to avoid being struck. Thisdefensive action then causes the defendant to strikeanother car and injure the claimant. A trier of factcould find that the defendant being forced to swerveinto plaintiff’s lane was not unreasonable underthose circumstances.

Take another example involving a rear-end car acci-dent. If the defendant can prove that he was in con-trol of his vehicle and followed the plaintiff at asafe distance, but an unexpected hazard in the road-way caused him to strike the lead driver, the trier offact would assess whether the defendant’s conductwas reasonable in light of this hazard. In addition,the trier of fact could ultimately find the driver wasnot negligent. Put another way, the driver’s duty notto follow too closely to traffic ahead would be as-sessed under the conditions at the time of the acci-dent.

Contributory negligence. Contributory negligenceexists in four states and the District of Columbia. Inthese jurisdictions, if the plaintiff caused or contrib-uted to the accident in any degree, even if only 1%,the plaintiff is barred from recovery.

In a rear-end collision, there might be circum-stances in a claim that, for example, the lead driver

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Construction Litigation, Products Liability, Personal Injury Defense, General Liability,Property, Fire & Casualty Claims, Directors and Officers Litigation, Errors and

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Applying SIU roots and unique talents in a case by case approach, TLG not only advisesits clients about the law, but provides practical solutions they can utilize every day. TLG

goes the extra mile to give its clients the ability to make informed and educateddecisions, and to offer creative solutions to complicated legal problems.

Thenell Law Group provides you with options,solutions and a partnership for success.

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came to an unnecessary stop, moved in reverse, orthat the lead driver’s brake lights failed to function.In an improper left turn accident, there might befacts that the defendant reasonably believed he hadsufficient time to clear the intersection, but that theplaintiff was speeding and that contributed to theaccident. This could result in a finding of contribu-tory negligence and preclude the plaintiff from anyrecovery.

Comparative negligence. Comparative negligenceallocates fault amongst all drivers involved in anaccident wherein a driver’s liability can be reduced,if the other driver is, in part, at fault for causing theaccident. Unlike contributory negligence which ex-ists in only five jurisdictions, most states use someform of comparative negligence. There are twomain variations to this system: Pure comparativenegligence and modified comparative negligence.

In a pure comparative negligence jurisdiction, dam-ages awarded are apportioned according to the per-centage of fault. That means that if, for example, thedefendant is found to be 70% liable for the accident,the plaintiff recovers 70% of her damages. Althoughnot a complete bar to recovery, pure comparativenegligence jurisdictions still permit for the amountof damages awarded to the plaintiff to be reduced inan amount corresponding to the degree of fault at-tributed to the lead driver. In an extreme case wherethe plaintiff was found to be 70% at fault, thatwould reduce the plaintiff’s damages award to only30%.

The other version is known as the modified com-parative negligence system in which liability isagain apportioned based on the percentage of fault,but the plaintiff only recovers damages if she is lessthan 50% responsible for causing the accident. If theplaintiff were to be found 51% or more liable, thenshe is barred from any recovery.

Damages. Lawyers often refer to cases as havingtwo components: liability and damages. In doingso, claimants frequently overlook that damages are,in fact, an element to the negligence action, mean-ing the plaintiff must prove by a preponderance ofthe evidence that her damages were caused by theaccident to win at trial. Included with that elementof damages is the legal requirement that a plaintiffmust mitigate damages, meaning she owes a dutynot to make her injuries worse.

OCAA — M ay 2019OCAA — M ay 2019 - 17 -

came to an unnecessary stop, moved in reverse, orthat the lead driver’s brake lights failed to function.In an improper left turn accident, there might befacts that the defendant reasonably believed he hadsufficient time to clear the intersection, but that theplaintiff was speeding and that contributed to theaccident. This could result in a finding of contribu-tory negligence and preclude the plaintiff from anyrecovery.

Comparative negligence. Comparative negligenceallocates fault amongst all drivers involved in anaccident wherein a driver’s liability can be reduced,if the other driver is, in part, at fault for causing theaccident. Unlike contributory negligence which ex-ists in only five jurisdictions, most states use someform of comparative negligence. There are twomain variations to this system: Pure comparativenegligence and modified comparative negligence.

In a pure comparative negligence jurisdiction, dam-ages awarded are apportioned according to the per-centage of fault. That means that if, for example, thedefendant is found to be 70% liable for the accident,the plaintiff recovers 70% of her damages. Althoughnot a complete bar to recovery, pure comparativenegligence jurisdictions still permit for the amountof damages awarded to the plaintiff to be reduced inan amount corresponding to the degree of fault at-tributed to the lead driver. In an extreme case wherethe plaintiff was found to be 70% at fault, thatwould reduce the plaintiff’s damages award to only30%.

The other version is known as the modified com-parative negligence system in which liability isagain apportioned based on the percentage of fault,but the plaintiff only recovers damages if she is lessthan 50% responsible for causing the accident. If theplaintiff were to be found 51% or more liable, thenshe is barred from any recovery.

Damages. Lawyers often refer to cases as havingtwo components: liability and damages. In doingso, claimants frequently overlook that damages are,in fact, an element to the negligence action, mean-ing the plaintiff must prove by a preponderance ofthe evidence that her damages were caused by theaccident to win at trial. Included with that elementof damages is the legal requirement that a plaintiffmust mitigate damages, meaning she owes a dutynot to make her injuries worse.

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Plaintiff’s lawyers anticipate a defendant will assertthat the plaintiff exaggerated her injuries or over-treated to enlarge her claim. However, the defenseon damages does not stop there. Rather, a defenseon damages should take into account whether theplaintiff missed any treatment, failed to follow thedoctor’s orders or recommendations, or did notlimit certain activities as that could worsen an in-jury. A thorough review and analysis of the plain-tiff’s medical treatment and corresponding recordsare critical to defending a negligence action forbodily injuries.

Although car accidents cannot always be won attrial, it is not impossible. It is, however, critical togather all details from the insured driver and have aclear understanding of all facts and circumstancesof the incident before accepting liability. If the factssuggest or support any of the defenses above, it isworth investigating with defense counsel.

— Marie J. Ignozzi ([email protected]) is an accomplished trial lawyerat Wright, Constable & Skeen, LLP in Baltimore, Maryland, where she fo-cuses her practice on insurance coverage and defense.

Oregon Supreme Court ReaffirmsThat Restaurants and Taverns DoHave Immunity For “First Party”Claims of Over-Service of Alcohol

In 2017, the Oregon Court of Appealssent shockwaves through the hospitalityindustry when it held that a section of

Oregon’s liquor liability statute was unconstitutionalbecause it denied a severely injured, intoxicated driver aremedy for her injuries allegedly caused by a socialhost. As expected, the Oregon Supreme Court acceptedreview. My star senior counsel Jeremy Reeves and Isubmitted extensive amicus curiae briefing addressingthe flaws in the court of appeals’ constitutional analysisand why the entire statute passes constitutional muster.We expected that the Supreme Court would use the caseto settle the issue of whether the court of appeals erredin holding the statute unconstitutional. Did it? Read onto find out.

Claims Pointer: With potentially dramatic implicationsfor any business that serves or sells alcohol, the OregonSupreme Court reviewed the court of appeals’ opinionholding a portion of Oregon’s liquor liability statuteunconstitutional. Rather than explicitly addressing theconstitutional issue, the Supreme Court simply affirmedthe court of appeals’ ruling on other grounds. Fortu-nately for the hospitality industry, this Supreme Courtdecision means that Oregon’s liquor liability statutecontinues to provide immunity for first-party claims forover-service. However, this case potentially opens thedoor to claims against social hosts when operating in adual function, such as operating as an employer and asocial host.

Schutz v. La Costita III, Inc., et al., 364 Or 536 (Mar.14, 2019)

We discussed the facts underlying this matter in a previ-ous case update and, in short, Ashley Schutz (“Schutz”)was seriously injured after drinking to intoxication withco-workers and then driving the wrong way on a free-way exit ramp. She had been employed by O’BrienConstructors, LLC as a temporary office assistant andjoined her co-workers and supervisor for drinks at a lo-cal La Costita restaurant. Schutz originally sued the res-

Oregon Case LawUpdate: DisturbingCourt of AppealsDecision Reversed

From the desk of Jeff Eberhard:

Case Study

OCAA — M ay 2019OCAA — M ay 2019 - 19 -

Plaintiff’s lawyers anticipate a defendant will assertthat the plaintiff exaggerated her injuries or over-treated to enlarge her claim. However, the defenseon damages does not stop there. Rather, a defenseon damages should take into account whether theplaintiff missed any treatment, failed to follow thedoctor’s orders or recommendations, or did notlimit certain activities as that could worsen an in-jury. A thorough review and analysis of the plain-tiff’s medical treatment and corresponding recordsare critical to defending a negligence action forbodily injuries.

Although car accidents cannot always be won attrial, it is not impossible. It is, however, critical togather all details from the insured driver and have aclear understanding of all facts and circumstancesof the incident before accepting liability. If the factssuggest or support any of the defenses above, it isworth investigating with defense counsel.

— Marie J. Ignozzi ([email protected]) is an accomplished trial lawyerat Wright, Constable & Skeen, LLP in Baltimore, Maryland, where she fo-cuses her practice on insurance coverage and defense.

Oregon Supreme Court ReaffirmsThat Restaurants and Taverns DoHave Immunity For “First Party”Claims of Over-Service of Alcohol

In 2017, the Oregon Court of Appealssent shockwaves through the hospitalityindustry when it held that a section of

Oregon’s liquor liability statute was unconstitutionalbecause it denied a severely injured, intoxicated driver aremedy for her injuries allegedly caused by a socialhost. As expected, the Oregon Supreme Court acceptedreview. My star senior counsel Jeremy Reeves and Isubmitted extensive amicus curiae briefing addressingthe flaws in the court of appeals’ constitutional analysisand why the entire statute passes constitutional muster.We expected that the Supreme Court would use the caseto settle the issue of whether the court of appeals erredin holding the statute unconstitutional. Did it? Read onto find out.

Claims Pointer: With potentially dramatic implicationsfor any business that serves or sells alcohol, the OregonSupreme Court reviewed the court of appeals’ opinionholding a portion of Oregon’s liquor liability statuteunconstitutional. Rather than explicitly addressing theconstitutional issue, the Supreme Court simply affirmedthe court of appeals’ ruling on other grounds. Fortu-nately for the hospitality industry, this Supreme Courtdecision means that Oregon’s liquor liability statutecontinues to provide immunity for first-party claims forover-service. However, this case potentially opens thedoor to claims against social hosts when operating in adual function, such as operating as an employer and asocial host.

Schutz v. La Costita III, Inc., et al., 364 Or 536 (Mar.14, 2019)

We discussed the facts underlying this matter in a previ-ous case update and, in short, Ashley Schutz (“Schutz”)was seriously injured after drinking to intoxication withco-workers and then driving the wrong way on a free-way exit ramp. She had been employed by O’BrienConstructors, LLC as a temporary office assistant andjoined her co-workers and supervisor for drinks at a lo-cal La Costita restaurant. Schutz originally sued the res-

Oregon Case LawUpdate: DisturbingCourt of AppealsDecision Reversed

From the desk of Jeff Eberhard:

Case Study

OCAA — M ay 2019OCAA — M ay 2019 - 20 -

turned summary judgment and remanded the case fortrial on all claims. Defendants petitioned the Oregon Su-preme Court for discretionary review, which the courtaccepted.

At the Supreme Court, Defendants argued that the courtof appeals had erred in finding the liquor liability statuteunconstitutional. Our firm and the Oregon Liability Re-form Coalition each submitted amicus curiae briefs insupport of Defendants’ position. Our briefing focusedon the court of appeals’ cursory and erroneous analysisof the application of Oregon’s remedy clause to Ore-gon’s liquor liability statute and the detailed legislativehistory that supported its constitutionality. The OregonLiability Reform Coalition’s brief focused on the danger-ous expansion of judicial powers and associated viola-tion of the separation of powers at issue if the opinionwas left standing.

Notwithstanding this backdrop, the Oregon SupremeCourt determined that the question it was required toanswer was not whether the statute was constitutional,but rather “whether a defendant who fits the definition ofa server or social host is immune from liability onlywhen alleged to be acting as a server or social host oralso when alleged to be acting in another role, such asproperty owner or employer.”

Based on this question, the court engaged in statutoryinterpretation of the liquor liability statute. As usual, itbegan with the plain text of the statute itself. For pur-poses of its review, it distilled the statute into two sec-tions: (1) “a patron or guest who voluntarily consumesalcohol cannot bring an action against licensed servers orsocial hosts serving…alcoholic beverages, even thoughthe beverages are served to a patron or guest who is visi-bly intoxicated”; and (2) “the provision’s immunity appl[ies] only to claims relief based on injuries caused byintoxication” and “the provision’s immunity does notapply to claims for relief based on injuries caused bynegligent or intentional acts other than the service of al-coholic beverages to a visibly intoxicated patron orguest.” (emphasis in original) (internal quotation marksomitted).

The Court identified two plausible interpretations of thestatute. The first plausible reading, advocated for bySchutz, was that: “the immunity provided for claimsagainst servers and social hosts extends only to a limitedset of claims—claims in which the plaintiff’s injurieswere caused, at least in part, by the plaintiff’s own in-toxication—but does not extend to claims in which theplaintiff’s injuries also were caused by a defendant’s tor-tious acts other than the service of alcoholic beverages.”The second plausible reading, advocated for by Defen-dants, was: “that the immunity provided for claimsagainst servers and hosts extends to all claims in which aplaintiff’s intoxication causes the plaintiff’s injury, in-

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taurant, La Costita, where she consumed alcohol, aswell as O’Brien Constructors, LLC and her direct super-visor, Keeley O’Brien. After La Costita was dismissedfrom the action on summary judgment, Schutz contin-ued her lawsuit against the Keeley O’Brien and O’BrienConstructors, LLC (“Defendants”).

The remaining Defendants also moved for summaryjudgment, asserting that, as social hosts, they were enti-tled to the same immunity from Schutz’s claims as LaCostita – citing Oregon’s liquor liability statute, ORS471.565(1), which states (underlining added):

“A patron or guest who voluntarily consumes alco-holic beverages served by a person licensed by theOregon Liquor Control Commission, a person hold-ing a permit issued by the commission or a socialhost does not have a cause of action, based on stat-ute or common law, against the person serving thealcoholic beverages, even though the alcoholic bev-erages are served to the patron or guest while thepatron or guest is visibly intoxicated. The provi-sions of this subsection apply only to claims forrelief based on injury, death or damages caused byintoxication and do not apply to claims for reliefbased on injury, death or damages caused by negli-gent or intentional acts other than the service ofalcoholic beverages to a visibly intoxicated patronor guest.”

In response, Schutz argued that her claims against heremployer should be allowed to continue because theyalleged negligent acts “before she went to the bar wherealcohol was served.” Schutz argued in the alternativethat the statute was unconstitutional under Oregon’sconstitutional remedy clause. The trial court rejectedboth arguments and granted summary judgment to De-fendants. Schutz appealed.

The Court of Appeals held that in enacting the liquorliability statute, “the legislature had intended to elimi-nate the common-law claim of a voluntarily intoxicatedperson—no matter what the specification of negligence,so long as the injury was ultimately caused by voluntaryintoxication.” Because Schutz’s injuries arose from hervoluntary consumption of alcohol, statutory immunityapplied to all claims – meaning summary judgment wasappropriate.

However, the court of appeals wasn’t done and it nextanalyzed Schutz’ constitutional argument. In shockinglyconclusory fashion, the panel held that the liquor liabil-ity statute “was unconstitutional because it retained cer-tain common-law duties but denied plaintiff any remedyfor breach of those duties.” Thus, having determinedthat the first party immunity section of the liquor liabil-ity statute (set out in full above) was an unconstitutionalviolation of Oregon’s remedy clause, the panel over-


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today’s claim professionals.

lative history that clearly denoted that the bill was in-tended to preclude “all claims by patrons whose injuriesare caused, even in part, by their intoxication,” the Courtdetermined that the legislative history supported its con-clusion that “ORS 471.565(1) grants immunity to li-censed servers or social hosts only when patrons orguests bring claims against them in their roles as serversor hosts and only when voluntary intoxication was acause of the alleged injuries.”

With that conclusion in hand, the Court determined thatSchutz’s claims against Defendants Keeley O’Brien andO’Brien Constructors could survive because they werenot based entirely on their actions as social hosts, butrather, included negligence claims based on their actionsas her employer and supervisor(s). The Court was care-ful to say that it was not deciding that the plaintiff’s neg-ligent employment/supervision claims against her em-ployer were valid – that issue was left to the trial courton remand – merely that all claims were not automati-cally prohibited by the liquor liability statute. In fact, theSupreme Court offered a footnote that will limit the po-tential claims that may be brought against social hosts.Specifically, it wrote that “[o]ne allegation that maycross the line [against a social host] is plaintiff’s allega-tion that [Defendant] Keeley O’Brien was negligent in‘supervising an employee function at defendant La Cos-tita’s facility.’”

Moreover, although it was not directly at issue in thisappeal, the Court went out of its way to note that the ear-lier court of appeals decision, dismissing the claimsagainst defendant La Costita, was properly decided andthat all the plaintiff’s “first party” claims against the tav-ern itself were barred by the liquor liability statute. Thecourt explained that even claims such as failing to stopplaintiff from driving or failing to arrange alternativetransportation arose from the taverns’ role as a server ofalcohol and were therefore properly barred under thestatute – or in the words of the Oregon Supreme Court“La Costita was entitled to immunity”.

We believe that the Supreme Court should have utilizedthis case to affirm the constitutionality of the liquor li-ability statute. Nonetheless, the opinion does, in effect,affirm the continued viability of the liquor liability stat-ute in terms of providing immunity for servers of alcoholwithin the hospitality industry and social hosts when act-ing solely in the capacity as a server of alcohol. As aresult of the Court’s refusal to examine the liquor liabil-ity statute’s constitutionality, we anticipate that someplaintiffs, injured as a result of their own intoxication,will again attempt to challenge the statute on constitu-tional grounds. When that happens, we stand ready toprove that the statute is constitutional. — View full opinion at: https://cdm17027.contentdm.oclc.org/digital/pdf.js/web/viewer.html?file=/digital/api/collection/p17027coll3/id/7124/download#page=1&zoom=auto

cluding those claims in which the plaintiff alleges thatthe server or social host committed a tortious act otherthan the service of alcoholic beverages.”

Schutz argued that her claims against defendants wereviable because “although her intoxication may havebeen one cause of her injuries, her injuries also werecaused by defendants’ tortious acts in their roles as heremployer and supervisor, and the statute does not barsuch claims.”

The Court sided with Schutz—describing her interpreta-tion as the “most plausible.” The Court provided threereasons: (1) Defendants’ reading that there was only onecause of Schutz’s injuries (i.e., her voluntary intoxica-tion) made “neither logical nor legal sense”; (2) Defen-dants’ reading of the statute would render the secondclause (i.e., that “the provision’s immunity does not ap-ply to claims for relief based on injuries caused by neg-ligent or intentional acts other than the service of alco-holic beverages”) meaningless; and (3) the language inthe second sentence—that the provision “appl[ies] onlyto claims for relief based on intoxication”—was in-tended to narrow the circumstances in which immunityapplies, not to allow the provision to apply “whenever aplaintiff’s injuries are caused by intoxication.” In sum,the Court held that the text of the liquor liability statute“provides immunity for claims against servers and so-cial hosts only for their actions as servers or socialhosts” and that “servers or social hosts who are not suedin their capacity as servers or hosts, but rather, in someother capacity, are not entitled to immunity.”

Although the Court’s interpretation of the text of thestatute seems to be the basis for its decision, the opinionalso analyzed the legislative history in support of itsreading – specifically, the statute’s 2001 amendments,which were proposed and enacted by Oregon’s legisla-ture in direct response to the holding in Fulmer v. Tim-ber Inn Restaurant and Lounge, Inc., 330 Or 413 (2000).Fulmer allowed a claim against a tavern by an intoxi-cated patron who was injured when he had difficultydue to his intoxication in navigating a set of stairs thatwere otherwise safe and sound. The legislative amend-ment overruled Fulmer, expressing clearly that no claimexisted for that situation, but still permitting an intoxi-cated patron to bring claims where “a ripped carpet, abad handrail, a broken stair, contributed to the acci-dent…” (italics in original).

In order to accomplish that goal, an amendment, whichbecame the second sentence of ORS 471.565(1), wasproposed by the Oregon Trial Lawyers Association inorder “to provide that, although servers would be im-mune for their actions as servers, they would not be im-mune for their actions as property owners.” Accordingto this version of history and notwithstanding the Courtconceding that there were comments made in the legis-

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OCAA Meeting Minutes Tuesday, April 9, 2019Past Presidents: Mike Meadows and Judy DaufelGuests: Hillary Boyd, Hugh Morris, Cindi Adams

Reading of Minutes: Waived.Report of Treasurer: General fund $11,572.38; Scholarshipfund $2,738.00.Report of Pres. Elect: None.

Committee Reports:— Symposium, really close, 4/25 Holiday Inn Wilsonville.There will be prizes, breakfast and lunch and Happy Hour.— Golf at Stone Creek will be Friday, July 12 with a tee off8:00am Shotgun start.

Unfinished Business: Next meeting May or June? No summermeetings.

General Discussion:September meeting Happy Hour Kickoff

Speaker: Patrick Riedlinger, Envista Forensics on AdvancedTopics in Accident Reconstruction.

Member Drawing: $50.00 no winner. Cryin Corner: MaryLuttrell; Michael Gatewood, Cunningham Lindsey; Jeri Gil-strap, Davis Rothwell; Glenn Rennemann, Sedgwick; LloydDykes, EFI Global.

Respectfully submitted by Brian Beaudry, Secretary.

oregonoregoncasualtyadjusters.org/articles/ocaa news may 2019.pdfvista forensics! we trust he made...

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