RECEIVED

RE: OAH Docket 01-2020-INS-00072 MAR 102020 OAH-TACOMA To Whom It May Concern:

I am writing this with somewhat of a handicap as it would seem I am the only one without access to emails and texts for the time period in question. When I left Sentry Insurance in June of 2018, I also lost access to all emails and text messages that were sent during that time period. I also loss access to my calendar and notes which I used to keep notes and reminders. One of the injuries that I received during combat while serving in the Army was repeated Concussions from blast while serving in Iraq. I say this only as my memory is at a loss without my notes. I can remember most items by dates and times are often jumbled. My timeline of the events will not have any dates or times used with them either. Lastly as a single father and realizing the importance of this hearing I simply do not have the finances to hire an attorney. Please forgive in advance that when reading my response and realizing in may not be presented in a way in which you may be familiar with.

I began working with Sentry Insurance in September of 2011. This was my second job after being Medically Retired from the Army. I was assigned the territory of NW (North of 1-90 West of the Cascades) and all of . I would visit insured and prospects in person in both parts of my territory. My trips to Alaska would be limited to once a month for 4 days when travel to and fro are excluded. When I began with Sentry I was part of a Division called Dealer Operations. We had our own Underwriters, Customer Service Representatives, Support Staff, and Management. At this time all calls were log into a CRM called Saratoga and all request were sent in Manually. For changes to existing policies there was a tool on Saratoga called a PCN (Policy Change Notice). As timed moved on with my employment with Sentry changes in structure changed (this is important for Alaska). Saratoga become obsolete, there was a CRM change to MS Dynamics, Sentry switched to an online format rather than manual PCN requests, and merged divisions. This all happened for all states except Alaska. Alaska was not switched to the new format of online format and remained on a manual request basis. This was for all things including application for new business, renewals, PCN, requests, and Certificates of Insurance. During this time period I went thru many Underwriter changes. Getting anything put thru for Alaska would take repeated attempts and took longer than normal request due to Manual versus Automated systems. This was confusing to me because I was using two systems at the time having territories in both Washington and Alaska. Sentry issued us Laptops and Surfaces during my tenure. Both had internet capacity unfortunately that internet capacity was severely limited in Alaska. Sentry used Verizon which is great in the lower 48 unfortunately not so well in Alaska. They made an exception for me giving me access to AT&T in Alaska but as I would find out later this was limited as well. I give this background to help explain how and why I get to where I am now. The account in question is a (forgive me because I am going off simply memory) Body shop in Alaska. The owner married Carrie Anne and they were great insureds. I inherited them as they were on a preexisting book before I was hired. I remember them both well because they were both involved in Bodybuilding and competed in Bodybuilding events in Seattle. One first approached by the insureds that they were considering opening an exercise place they sent me the address of the location. I sent in the PCN request to add the new location and was instructed to take pictures of the location and send them in to Underwriting. On my next trip to the city I took the pictures that were requested and submitted them to as instructed. The location was added correctly, and the Certificates issued were correct and approved by the insured. This is important because during this time the PCN tool was still be used by all associates, we still had our own Underwriters, Customer Service, and support. My Underwriter at the time is the only Underwriter I remember the name of Chris Larson. I remember his name because he moved from Davenport (the home office for my division at the time) to Washington. Some time later the insured moved the location of the facility to a different location. I cannot remember the date. It was a considerable time later. I do remember recommending to her that she get separate insurance and even emailed her an application from a broker outside of Sentry that insureds actual fitness centers. She was not interested in this and reaffirmed that this was a small endeavor and she did not want to fill out the application and wished to keep things as they were. I remember sitting with her and doing the PCN to change the location. During this time Sentry went to the all online request and PCN were manual. After completing the PCN request and submitting it in there was a long period of time where I had heard nothing from Carrie. I then received a calf stating she needed a COi for the new location. I requested the COi and submitted to Carrie. A period went by and made several trips to Alaska and even met with Carrie more than once. I was informed by her that the COi was incorrect and needed an ANI added. I submitted the PCN. Normally when the PCN is submitted the COi is sent directly to the insured. Carrie did not receive the COi. During this time period there were a lot of items slipping thru the cracks especially with the only State still on a Manual system. Sentry had now gone thru a massive transformation. Merging two divisions and going fully automated. During this time period I lost all my underwriters I was familiar with, my customer service team I was accustomed to working with and was working with two systems. I found out that many of my request did not either go thru period because of email address I was accustomed to using was no longer monitored, did not go thru because of limited internet connectivity while in Alaska, and I got confused and did online changes when they needed to be done manually. Carrie became increasingly frustrated that she had not received her COi. I mentioned this to a former co worker and was given the suggestion to simply do the COi myself and send to Carrie while waiting for it done the appropriate way. I did not think this would be that big of a deal since I (so I thought) sent in the proper PCN and the system would catch up. I did not think another thing about it until I received a call from Carrie several months after I left Sentry that the new Representative that replaced me could not give her the COi she needed. We had several conversations via the telephone where she expressed her concern. I remember she told me she had a very good friend with the Alaska Insurance Commissioner's Office, and she had talked to him about it but since she had resolved the situation on her end she would not submit a complaint. I expressed my concern and my sincere apologies to her. Over a year later I received the call from a person within the Alaska Insurance Commissioner's office stating that a complaint had been filed. My tenure with Sentry did not end in good terms there is a tremendous amount of animosity, anger, and distrust on both sides. It would appear that money of the quotes and information the investigator got was from the representative that replaced me, my former Regional Manager, and I cannot remember the title of the person above him title. I remember talking with the investigator and thinking to myself that I need to get a copy of his investigation so I could personally sue those people because much of the information they gave him was simply conjecture, hyper ably, and not true. When I left Sentry I received immediate employment at Rice Insurance. A Brokerage based in Bellingham Washington with offices in Issaquah. I know longer had any need for my Alaska Producers License. At Rice Insurance I have several Account Managers and Customer Service Reps that work directly with me. The investigator from Alaska then called me again an we went over the charges and was told all this via the phone not writing in an extremely casual call that we could put this situation to rest by me simply giving up my Alaska License and not seeking again in the future. He then said if I wanted to appeal this, I would have to do it in person in the State of Alaska. Since I have no business, need, nor interest in the State of Alaska I agreed. I had no idea this would impact my ability to have a career in the State of Washington. If I did, I would definitely go back in time and change the way I interacted with him. In my almost 10 years working within the insurance industry as a Producer I have, other than this, never received a complaint or negative review. I do realize that I should not have issued the COi myself and would never again do that. In fact the position that I am in I would not even have that opportunity. I did not and have not received any financial gain from the decision to issue said COi. I am a 46-year-old Veteran who is a single father losing my license and effectively career seems an extremely harsh penalty for this one transgression. I am throwing myself at the feet and begging forgiveness for this transgression and am hoping to come up with a penalty other that losing my License and allow me to provide for myself and my children. I am more than'willing to due any combination of Probation, Fine, or Volunteer Work. I realize my transgression was on of line and will never do anything of such again. I have been exemplar in my career other than this. I received no financial gain. I would like to thank you in advance for reading my appeal and look forward to meeting with you during hearing to further explain. I am praying and hoping we can come to an agreement.

Sincerely

James Lubitz March 6, 2020