[Letter from Isaac H. Kempner to Liberty Mutual Insurance Company, May 3, 1958] Page: 1 of 2

                                
Liberty Mutual Insuaic Co    ny
2120 Travis Street
Resident Manager
planation.
I placed thisi andt other insurance with you,  r. aUC.ir
several years ago as a result of the impression you personally madc
on us here when you solicited the business. I felt I could rely
on you and the company you represented not to adopt technical denial
of liability and we established a record of not making technical
or questionable claims on your company. In this case with but a
small amount involved and I believe the general liability of the
company unquestioned, you are seeking to evade payment for the
damages incurred because of the wcrd' collision which I ha:vened i
use in presenting the claim.
As a matter of fact, you don't know and I don't know hiL
this accident happened. The automobile was parked in front of
residence. At just about dusk we noticed a number of cars being
diverted off their normal course on Broadway, this about 7 P. Y.
It was not until the next morning that we knew the car had been
damaged, probably twenty-four hours after the incident occurred.
There had been a collision between some fast driving motorcyclists
and an automobile some fifty yards away from where our car was
parked. We had no way of knowing what had happened until we saw
the car in daylight. In presenting the claim I did use the word
collision as it seemed that the car was damaged by another car,
but whether it backed into it, whether the other car was going at
a high rate of speed or going at a low rate of speed with the
driver having his eye on the crowd which an accident always draws,
I don't know and you don't know.
Personally I am not of the opinion that collision stew
as near certain in this case as collusion seems in avoiding payment.
Let me have your final decision and I will be governed accordingly.
Yours very trt y,

11