1. There is been no independent management committee associated “Rice Creek Townhouses” from 2011 to the present.
2. Rice Creek Townhouse company is a Minnesota limited partnership. The general partner is W-L-Associates a Minnesota general partnership. It acts through James E. Weinsch, a general partner. There is no board of directors for Rice Creek Townhouse Company. Mr. Weinsch has the most knowledge of this history of the …show more content…
buildings and roofs.
3.
There were no property tax returns filed for Rice Creek Townhomes, from 2011 to the present, as they were not required.
4. Our understanding is that EMC has insured the property since 2000. Your insurance agent was able to provide us with a loss data report going to back to 2007. The claims history is attached as Exhibit 1. We note that this information was available to EMC, but we are providing the same as requested. In that regard, we ask that you check the time periods of 2000-2006 through your client’s own records. Prior to 2000, the property was insured by Ohio Casualty, which we understand was purchased by Liberty Mutual. We have no information with respect to those requested items or policies.
5. As noted above, the claims history is attached as Exhibit 1.
6. A list of the work performed and repairs made to the roof and claimed property is attached as Exhibit 2.
7. The real estate was purchased as unimproved property in approximately 1974. There is no documentation relating to that purchase available to our client. Any mortgage in connection with the property has long since been paid in full.
8. The information requested in our letter is referenced in our attached Exhibit
3.
9. Our client did not engage in “correspondence” with creditors or persons to whom Rice Creek Townhouse Company owed money in the 12 months preceding the loss, other than receiving invoices in the ordinary course of business and mailing the third party a check in payment of the amount owed to them. Candidly, obtaining this information would require a substantial burden on the part of our client, and does not appear to related to any insurance coverage questions that we have observed.
10. Any information that we have is referenced in our attached Exhibit 4.
11. See no. 10 above; our client does not prepare mid-year balance sheets.
With respect to questions 12 through 14, these questions can most likely be addressed by Mr. Scott Gann whose examination under oath has been currently scheduled.
We trust that this assists your continuing investigation. Please contact the undersigned if you have any questions or comments.