IN REGARD TO:
RENO MOATS
CLAIM NOS:
11–541-6745
11–561-6544
* * *
The following examination under oath of RENO MOATS was scheduled to have been taken before Tanga Donnelly, Certified Court Reporter in the State of Georgia, on Wednesday, June 22, 2011 at 4250 International Boulevard, Norcross, Georgia; to have commenced at 11:00 a.m.
PO BOX 1442
Snellville, Georgia 30078
770-985-2344
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A P P E A R A N C E S
ON BEHALF OF PROGRESSIVE INSURANCE COMPANY:
BRAD MACK
4250 International Boulevard
Norcross, Georgia 30093
(687) 380-3286
ALSO PRESENT:
Beth Shroat
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EXHIBITS
Page Marked/
Exhibit No.DescriptionIdentified
1Letter to Moats5/5
2Track & Confirm5/5
TRANSCRIPT LEGEND
-(Interjection of thought for clarification)
-- (Interruption of thought)
...(Trailing off or did not complete thought)
(ph)(Phonetically)
[sic](In its original form)
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P R O C E E D I N G S
12:00 p.m.
MR. MACK: If we can go ahead and go on the record. For the record, my name is Brad Mack. I am an investigator with Progressive Group of Insurance Companies. Today's date is June 22, 2011. The time is 12:01 PM and we are located at the Progressive claims office in Norcross, Georgia. The purpose of the attendance today is to conduct an examination under oath of Reno Moats. And this is in reference to a claim that he's made with Progressive under claim number 11–541-6745. That is a claim reference a motorcycle theft. There is also a dual vandalism claim, that is claim number 11–561-6544. The policy number for the motorcycle theft claim is Progressive policy number 17791091-1. And the policy number for the dual vandalism claim is going to be 65372475–2. This is reference a vandalism that occurred to his Ford F-350 truck and a theft to his Harley-Davidson motorcycle, which occurred on April 21st, 2011. And the address that we have is going to be Route 4, Box 68-C. This was in Clarksburg, West Virginia.
And also present today is SIU investigator Beth Shroat and I've got court reporter Tanga Donnelly with Metro Reporters. And I would like to go ahead and enter the first Exhibit. This is going to be a copy of the EUO letter that was sent to Mr. Moats. This was sent both certified mail and regular mail. And I will go ahead and list the postal tracking number. It's going to be 7010309000156585598. That's going to be the first Exhibit.
(Whereupon, the court reporter
marked Exhibit No. 1
for identification.)
MR. MACK: And then the second Exhibit is going to be the Postal Service tracking confirm reference that tracking number for that certified mail. On this information it states that the letter was received and sorting through the processing unit on June 3rd. And then it arrived to his house or it arrived at the unit on June 3rd at 5:18 a.m. in Nicholson, Georgia. A notice was left at his residence on June 3rd at 11:07 a.m. in Nicholson, Georgia. And then the certified mail was marked unclaimed on June 18th at 10:44 a.m. in Nicholson, Georgia.
(Whereupon, the court reporter
marked Exhibit No. 2
for identification.)
MR. MACK: The last contact with Mr. Moats was on June 1st, 2011. Five voice mails have since been left for Mr. Moats. One was left on June 3rd, June 7th, June 9th, June 15th, June 21st. Mr. Moats has not returned any of the voice messages left at any of those times, neither the confirmation to appear at the EUO has been returned or received by Mr. Moats. Mr. Moats did indicate that he would attend this EUO. When contact was made with him prior to June 1st, he agreed to this date and time. At no point has Mr. Moats communicated that he would not be attending today. And thus since he's not here he has not produced any requested documents. And now the time is 12:05 and it should be noted that he has not appeared for his examination under oath. No phone calls have been received today from Mr. Moats and with that, we are off the record.
(Whereupon, the deposition in the above-entitled
matter was concluded at 12:05 p.m.)
oOo
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C E R T I F I C A T E
STATE OF GEORGIA)
COUNTY OF CHEROKEE)
I hereby certify that an examination under oath of RENO MOATS was scheduled to have taken place on Wednesday, June 22, 2011, at 11:00 a.m.; that Mr. Moats failed to make an appearance; that I am not a relative, employee, attorney or counsel of any of the parties; am not a relative or employee of attorney or counsel for any of said parties; nor am I financially interested in the outcome of the action.
This the 23rd day of June, 2011.
______
Tanga Donnelly, CCR
Certified Court Reporter
License No. B-1868
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