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	"Affidavit - 2003 Mitsubishi Eclipse"

CONSUMER STATEMENTS FOR LEIFS.COM

The identities of the consumer, the insurance company involved, and the insurance-referred repair shop involved have been changed to protect their privacy.

IN THE CIRCUIT COURT FOR THE STATE OF OREGON

IN AND FOR THE COUNTY OF MULTNOMAH

LEIFS AUTO COLLISION CENTERS, LLC, an Oregon limited liability company,

Plaintiff

vs.

YYY INSURANCE COMPANY,

Defendant

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Case No. XXXXX
DECLARATION OF
LEIFS CUSTOMER XXX

I, LEIFS CUSTOMER XXX declare:

On or about May 10, 2004, my 2003 Mitsubishi Eclipse sustained collision damage. I made a claim with my insurer, ZZZ Mutual Insurance Company (aka “YYY Companies”), for the damage.

On about May 12, 2004, YYY1, a field adjuster for YYY Companies, inspected my vehicle and wrote a repair estimate. Mr. YYY1 appraised the damage without any “tear down” (removal of exterior parts and panels to reveal damage further inside the vehicle) performed on my vehicle.

On or about May 18, 2004, I took my vehicle to Leif’s Auto Collision Centers (“Leif’s”) to perform repairs to my vehicle.

It is my understanding that, on May 20, 2004, Mr. YYY1 met with Leif’s representative to review the damage after my vehicle had been torn down and to review Leif’s repair blueprint in-person at the shop. It is further my understanding that Mr. YYY1 denied payment for many necessary repair operations, including:
1. color sand and polish
2. clean for delivery
3. plastic/metal disposal
4. cover car exterior
5. prime block and fill
6. repair materials
7. flex additive
8. labor for edge and jamb of fender
9. Nib sanding ("De-nib")
10. Rebagging for primer

On about May 24, 2004, I met with Mr. YYY1 and Leif’s representatives at Leif’s shop. Mr. YYY1 refused to authorize payment for many of the necessary items. Mr. YYY1 was also extremely rude, making derogatory comments about Leif’s, including that Leif’s was dishonest and that it was my problem for taking my vehicle to Leif’s for repair. Mr. YYY1 also stated that I failed to inform him of a bend in the fender where the collision occurred (which was not readily discernable to me at the time and only became noticeable after Leif’s representative pointed it out) and that, according to Mr. YYY1, the bend must have happened sometime after the accident.

No one at YYY Companies has been willing to help me in this matter. It is my understanding that no one at YYY Companies has been willing to review this matter with Leif’s.

I authorize and give complete discretionary power to Leif’s Auto Collision Centers (“Leif’s”) to repair my 2003 Mitsubishi Eclipse as Leif’s solely deemed to be correct without regard to the repair times, procedures, parts, materials, and/or overall repair cost authorized by the insurance company, its representatives, and/or its independent appraiser.

I irrevocably assign to Leif’s all rights for payment for all amounts owed as a result of Leif’s repairing the Vehicle. This assignment includes any rights to attorneys fees. I grant Leif’s power of attorney to present and, if it chooses, to enforce claims for such repairs and payments directly against any party responsible for paying Leif’s repair.

I hereby declare that the above statement is true to the best of my knowledge and belief, and I understand it is made for use as evidence in court and is subject to penalty of perjury.

DATED this ___ day of ____, 2004

____________________________________
LEIFS CUSTOMER XXX