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HomeMy WebLinkAbout98-148RESOLUTION AUTHORIZING DISTRICT ATTORNEY TO UNDERTAKE GRANT AWARD AGREEMENT WHEREAS, the Butte County Board of Supervisors desires to undertake a certain program designated "Automobile -California Insurance Code Section 1872.8, California Code of Regulations Subchapter 9, Article 4, Sectian 2698.65 administered by the California Department of Insurance. NOW, THEREFORE, BE IT RESOLVED that the District Attorney of the Butte County District Attorney's Office is authorized, on its behalf to submit the attached proposal to the California Department of Insurance and is authorized to execute on behalf of the Board of Supervisors the attached. Grant Award Agreement including any extensions or amendments thereof. BE IT FUR"I'IIER RESOLVED that grant funds received hereunder shall not be used to supplant expenditures controlled by this body. I hereby certify that the foregoing is a true copy of the resolution adopted by the Butte County Board of Supervisors in a meeting thereof held on the 22nd day of September 1998, by the following vote: AYES: Supervisors Beeler, Dolan, Houx, Josiassen and Chair Davis NOES: None NOT VOTING: None ABSENT: None i" -` FRED C. DAMS, Chair Butte County Board of Supervisors ATTES"I~: JOI-IN BLAC,KLOCK, Chief Administrative Officer and Clerk of the Board of~Supervisors 7 ~' Resolution No . 98-148 DEPARTMENT OF INSURANCE GRANT APPLICATION TRANSMITTAL Office of the District Attorney, County of Butte ,hereby makes application for funds under the automobile fraud program pursuant to Section 1872.8 of the Insurance Code. Contact: Ed Szendre~, Chief Investigator Address: 25 County Center Drive Oroviile, CA 95965 7'etephone: (530) 538-7460 (1) Program ~'itl e Automobile Insurance Fraud Prosecution Program (4) Program Director Michael L. Ramsey District Attorney 25 County Center Drive Oroville, CA 95965 (6} District Attorney's Signature (2) Grant Period 7/1/98-6130/99 (3) Grant Amount (5) Financial Officer David Houser Butte County Auditor 25 County Center Drive Oraviile, CA 95965 Nam . cha L. R Title: District Attorney County: Butte Address: 25 County Center Drive Oroville, CA 95965 Telephone: (530)538-7411 Date: June 29, 199$ Butte County District Attorney APPLICATION FOR A PROGRAM FOR THE ITfVESTIGATION AND PROSECUTION OF AUTOMOBILE INSURANCE FRAUD Fiscal Year 1998-99 TABLE OF CONTENTS I. SECTION ONE 1. Grant Transmittal 2. Board of Supervisors Resolution 3. Program Contact Information II. BUDGET ELElV1ENTS A. Personnel (Salary and $enefits) B. Operating Expenses C. Equipment III. BUTTE COUNTY PLAN A. Qualifications B. Problem Statement C. Program Strategy D. Objectives E. Organizational Chart IV. JOINT INVESTIGATIVE PLAN PROGRAM CONTACT FORM 1 Provide the name, title, address and telephone number for the person having day-to-day responsibility for the program. Name: Guy Georgianna Title: Senior District Attorney Investigator Address: 25 County Center Drive Oroville, CA 95965 Telephone Number: (530)538-7735 Fax Number: (530)538-7071 2 3 4 Provide the name, title, address and telephone number of the Chair of the County Board of Supervisors. Name: Fred C. Davis Title: Chairman, Butte County Board of Supervisors Address: 25 County Center Drive Oroville, CA 95965 Telephone Number: (530)538-7643 Fax Number: (530)538-7120 Provide the name, title, address and telephone number for the District Attorney's Financial Officer. Name: David Houser Title: County Auditor Address: 25 County Center Drive Oroville, CA 95965 Telephone Number: (530)538-7607 Fax Number: (530)538-7693 Provide the name, title, address and telephone number for the person responsible for the data collectionlreporting for the applicant agency. Name: Donna Dulyea Title: District Attarney Investigator II Address: 25 County Center Drive Oroville, CA 95965 Telephone Number: (530)538-2046 Fax Number: (530)538-7071 II BUDGET ELEMENTS DEPARTMENT OF INSURANCE BUDGET CATEGORY AND LINE- ITEM DETAIL A. Personnel Services -Salaries/Employee Benefits COST District Attorney Investigator II (.5 FTE) Program Investigator. Devotes -Salary $19,132 50 % of time fo this program. -Benefits $11, 394 Senior Investigator (.10 FTE) Supervisor of Program. Devotes -Salary 4,217 9C1°lo of time to oversight of program -Benefits 2,428 and grant management. legal Secretary (.10 FTE) Clerical support for program. -Salary 2,541 Devotes 10% of time to this program. -Benefits 1,352 Deputy District Attorney III (.10FTE) Program Prosecutor -Salary 4,495 Devotes 10% of time to this program -Benefits 1,389 TOTAL -Personnel Services $46,948 DEPARTMENT OF INSURANCE COST 'B. Operating Expenses Transportation,Travel, and Training 2,000 Travel for meetings, case investigation, and program related training for investigator. (Office Expense General office supplies. 700 ransportation -Motor Vehicle 3,000 $500 per month is allocated for fhe use of vehicle assigned to project investigator. (500 X 12 = 6,000 X 1l2 = 3, 000) dit Annual expense for Program Audit 1,500 Adminsitrative Overhead 3,799 5% of total direct costs. Cost allocation plan in accordance with Federal OMB Circular A-87 is on file with the State Controllers Office. (Communication Expense Telephone, pager, and Cell Phone for Investigator 720 TOTAL -Operating Expenses ~ $11,719 ~ DEPARTMENT OF INSURANCE BUDGET CATEGORY AND LINE-ITEM DETAIL C. EQUIPMENT COST NONE TOTAL - Equipment 0 PROJECT TOTAL $58,767 III BUTTE COUNTS PLAN A. Qualifications COUNTY PLAN AUTOMOBILE INSURANCE FRAUD QUALIFICATIONS Prior to this time the Butte County District Attorney's Office has not actively participated in the Department of Insurance, Automobile Insurance Fraud Program. This has been, unfortunately, due to the perception we lacked the resources to address the problems of insurance fraud. Because of burdensome case loads, inadequate funding, and the lack a full appreciation of the scope of the problem, resources were not directed to the problem. This office has reassessed its responsibility to address the general issues of insurance fraud. We recognize with 185,000 vehicles registered in Butte County and the Department of Insurance reporting 114 cases of Automobile Insurance Fraud in this county for FY 97/98, we need to address the issue in a positive, professional manner. The District Attorney realizes the mind-set of this office has to be to aggressively address the issue of insurance fraud. In reassessing our position it became apparent resources to address the problem were available if we effectively took advantage of the funding and services provided by the Department of Insurance. This office now recognizes that with the resources of the Department of Insurance combined with the current resources of this department we can aggressively participate in the fight against automobile insurance fraud. Needed to address the issues of insurance fraud are adequate resources for prosecution, follow-up investigation, outreach, clerical support, and program coordination. Experienced staff in the form of Deputy District Attorney III, Claudia Wrazel, Deputy District Attorney Marc Noel, Senior Investigator Guy Georgianna, Investigator II Donna Dulyea*, and the Major Crimes Unit secretary are available. However, these staff members are already handling heavy case loads. The addition of insurance fraud cases requires additional staff to address the issue. Funding available through this grant alone would not be sufficient to hire a full time investigator in addition to the prosecutorial and clerical demands of an effective program. However, with the approval of this grant and the funding available through the Workman's Compensation Insurance Fraud Program sufficient resources would be in place to hire an investigator. (*In anticipation of receiving both the Automobile and Workman's Compensation Fraud grants, Donna Dulyea is the candidate this office will hire to fill the position). The overall plan is to provide I O% FTE of a Deputy District Attorneys time in the form of 5% of Deputy District Attorney III, Claudia Wrazel's time, and 5% of Deputy District Attorney III, Marc Noel's time (The structure of the Butte County Consolidated Courts necessitates dividing the case load between two attorneys), 10°l0 of Senior Investigator Guy Georgianna's time, 50% of Investigator Dulyea's time, and I O% of the Major Crimes Unit secretary's time, in place to develop the Automobile Insurance Fraud Unit Fraud Unit, and adequately handle the case load. Qualifications Page 2 To address Workman's Compensation Insurance Fraud, 50% of the time of Investigator Jos Van Hout, unit supervision and clerical support, as well as the contract services of Attorney Brigham Jones will be devoted to the cases. With these resources in place the Butte County District Attorney This will have the adequate resources to address insurance fraud issues. III BUTTE BOUNTY PLAN B. Problem Statement AUTOMOBILE INSURANCE FRAUD COUNTY FLAN PROBLEM STATEMENT Butte County is a semi-rural county with a papulation of 201,596 people. The largest city is Chico with a population of 52,746 (93,000 is claimed by the city for the Chico greater urban area); followed by the Township of Paradise 26,357 (with a claimed area of influence of 40,000); Oroville 12,603 (45,000 is claimed for the greater Oroville area); then Gridley 4,912 (with a claimed area of influence of 22,000 people). There are 185,000 vehicles registered in Butte County. Major employers include the University of California at Chico, various municipal, county, state and federal governments. Rice, almond, and walnut farming, along with lumber are the major industries of the area. The county has above average unemployment and an above average welfare population. As a economically depressed area a number of fraud issues are having to be addressed. The advent of Indian Gaming has also had an impact. Two casinos have opened in the Oroville area. A small increase in bad checks, theft, embezzlement, and fraud has been attributed to those suffering gambling losses. To date Butte County has not adequately addressed the issue of Automobile Insurance Fraud. Due to a perceived lack of resources and not fully appreciating the scope of the insurance fraud problem, commitment to the investigation and prosecution of these cases was very limited. Unfortunately, Butte County did not address the need by seeking funding from the Department of Insurance. Department of Insurance records show there were 114 cases of Automobile Insurance Fraud in Butte County in the Fiscal Year 1997-98. This clearly is a substantial caseload. A caseload that cannot be borne by the Department of Insurance alone. It is clear the District Attorney needs to aggressively participate in the solution to the problem. With the available funding this office makes a commitment of one-half investigator, and the necessary prosecutoral, administrative, and clerical support to aggressively address these suspected fraud cases. Butte County is now committed to join with the Department of Insurance in addressing these cases. III BUTTE C(JITNTY PLAN C. Program Strategy AUTOMOBILE INSURANCE FRAUD COUNTY PLAN PROGRAM STRATEGY The Butte County District Attorney Automobile Insurance Fraud Investigation and Prosecution Program strategy is based on staffing, resource development, and communications. Staffing: Putting the most qualified persons in the key positions. Prosecution of Automobile Insurance Fraud cases will be the responsibility of two Deputy District Attorneys. The division of the case load is necessitated the structure of the Butte County Consolidated Courts. Because of this all case loads in the Butte County District Attorney's Office are divided alphabetically. Deputy District Attorney III, Claudia Wrazel is a graduate of the USC School of Law, has seventeen years experience in criminal and civil law including ten years with the Los Angeles City Attorney's Office. Ms. Wrazel specializes in economic crime prosecutions and has prior experience in insurance law. Deputy District Attorney III, Marc Noel is a graduate of the Creighton University School of Law. He has nine years experience as a prosecutor. Prior to coming to Butte County Mr. Noel was a Deputy District Attorney in Contra Costa County. Mr. Noel also specializes in economic crime prosecutions. Investigation of Automobile Insurance Fraud Cases will be the responsibility of Investigator II, Donna Dulyea. Ms. Dulyea has been a District Attorney Investigator with the San Diego District Attorney's Office for twenty-two years. Prior to that she was a Police Officer for the City of San Diego. Since 1992 Ms. Dulyea has been a Supervising Investigator. Her assignments include major crimes, fraud, and environmental crimes. She was the 1991, Investigator of the Year, for the California District Attorney Investigators Association. Senior Investigator, Guy Georgianna, who will supervise Investigator Dulyea, will be responsible to see all requirements of the program are carried out. Mr. Georgianna has been with the Major Crimes Unit of the Butte County District Attorney's Office since 1991. He has over twenty-four years experience in law enforcement having worked for the San Bernardino County Sheriffs Department and the U. S. Drug Enforcement Agency. Mr. Georgianna specializes in Asset Forfeiture, Economic Crime, and Major Fraud cases. Clerical responsibility far the program belongs to Gloria Lind. Ms. Lind is the secretary far the Major Crimes Unit. She is a Supervising Legal Secretary. Ms. Lind has been employed with Butte County as a Legal Secretary far seventeen years. Resource Development: The development of resources for the Butte County District Attorney, Automobile Insurance Fraud Prosecution Program is already underway. We have met twice with the Department of Insurance and have received valuable information from Kathryn Scholz, Rick Plein, Hung Le, and Mary Spaid. We also met with the Shasta County District Attorney insurance fraud Investigator, Mike Baxter, to learn how that county has developed a successful program and recruit their assistance in training our department. All these sources have demonstrated their willingness to go out of their way assist us. Investigator Donna Dulyea is the pivotal key to the successful administration of our Automobile Insurance Fraud Prosecution Program. It will be her responsibility to maintain open lines of communication between the Department of Insurance, Deputy District Attorneys Claudia Wrazel and Marc Noel, the various insurace carriers, and this office. Investigator Dulyea will utilize all resources available to effectively manage the Automobile Insurance Fraud case load. To familiarize Investigator Dulyea with these resources, and to prepare her to be the facilitator of this program, this office will make her available to spend two to four days at the Sacramento Department of Insurance, Fraud Division; two to four days with the Shasta County District Attorney Insurance Fraud Unit: to attend all carrier sponsored training events; and all specialized training provided by the Department of Insurance. Investigator Dulyea will be making personal contact with carriers and law enforcement agencies in this areas to let them know our services are available and who to contact. Communications: From our view of the overall program, communications is the key element to not only insure adequate investigation and prosecution, but is essential to avoid duplication of effort and coordinate joint ventures with the Department of Insurance. In our Joint Investigation Plan specific guidelines have been established regarding communication between the investigator, the attorney, and the Department of Insurance. We will insure these guidelines are met. Please refer to the attached Joint Investigation Plan. All cases will be reviewed by Deputy District Attorneys Claudia Wrazel or Marc Noel, and follow-up investigation will be coordinated between Ms. Wrazel, Mr. Noel, Investigator Dulyea, and the Department of Insurance. Investigator Jos Van Hout of the Major Crimes Unit has developed a computerized case tracking system far this county's insurance fraud programs. Investigator Dulyea will be responsible for reporting new cases and case dispositions to the Department of Insurance. III BUTTE COUNTY PLAN D. Objectives COUNTY PLAN FY 1998-99 OBJECTIVES 1. Eight new investigations will be initiated during FY 1998-99. Knowledge that we are in the Automobile Insurance Fraud business will generate additional cases. Open lines of communication with the Department of Insurance, contact with carriers, and being available to take cases handled in the past by other counties will make this goal readily attainable. 2. Four new prosecutions will be initiated during FY 199$-99. Anticipating successful investigation of the eight cases initiated during this fiscal year, four prosecutions is a reachable goal. 3. No investigations will be carried over from the previous grant period. This is Butte County's first year in the program. However, the county is willing to receive cases under current investigation by the Department of Insurance. 4. No prosecutions will be carried over from the previous grant period. This is Butte County's first year in the program. III BUTTE COUNTY PLAN E. Organizational Chart BUTTE COUNTY AUTOMOBILE INSURANCE FRAUD ORGANIZATIONAL CHART DISTRICT ATTORNEY CHIEF CHIEF DEPUTY INVESTIGATOR DISTRICT ATTORNEY MAJOR Ct,.AUD1A WRAZEL CRIMES DEPUTY DISTRICT UNIT ATTORNEY III SENIOR DEPUTY DISTRICT INVESTIGATOR ATTORNEY III FRAUD INVESTIGATOR IV JClINT INVESTIGATIVE PLAN JOINT INVESTIGATIVE PLAN Memorandum of Understanding I . Introduction (a) The "parties" to this joint plan are the California Department of Insurance -Fraud Division, and the Butte County District Attorney's Insurance Fraud Unit. (b) The parties of this joint investigative plan recognize that the C.D.I. -Fraud Division was established to investigate allegations of insurance fraud throughout the State of California, and is the primary investigative agency in this field. However, while the headquarters for the Fraud Division in Central Northern California is based in Sacramento, its investigative responsibilities encompass twenty-five central and northern counties. Due to this considerable geographical territory, the number of referrals/cases, and the finite number of investigators available, the Fraud Division cannot reasonably be expected to devote its efforts in any one county. Thus the important need for an effective joint plan to address the problem of insurance fraud in each jurisdictional territory. 2. Statement of Goals (a) To promote a close working relationship between the DAs insurance fraud unit and the Fraud Division, based on dedication to the common goal of fighting insurance fraud, commitment to the highest professional and ethical standards, and mutual respect as law enforcement officers devoted to the pursuit of justice and the protection of the citizens of Butte County and the State of California. (b) To investigate in a timely manner, using professional standard and procedures, and prosecute when appropriate, as many identifiable cases of suspected insurance fraud as we can. (c) To achieve the best possible anti-insurance fraud program we can produce, through the efficient and effective use of the limited resources provided, and the promotion of awareness in this community that the serious problem of insurance fraud is being addressed in a meaningful way by law enforcement. 3. Receipt and Assignment of Cases Present law requires that an insurer who knows or reasonably believes that an act of insurance fraud has been committed, report this information to the Department of Insurance -Fraud Division and the local district attorney (Insurance Code section 1877.3). (a) When a suspected fraudulent claim (SFC) or a case referral package is received from insurer, it will be entered into a database, available for future reference. Bath parties will maintain a case tracking system to monitor all SFC's and case referral packages received. (b) Both parties will communicate on a regular, scheduled basis to discuss SFC's and case referral packages received, with the objectives being to avoid duplication of investigative efforts, and to insure that all referrals are being appropriately addressed. When a case is assigned for investigation, the assigning party will notify the other within ten working days. A monthly report regarding intake of SFC's and assigned cases will be generated by both parties and mailed to one another by the fifth working day of each month. (c} If the SFC or case referral package is sent only to the Fraud Division, the Fraud Division will address the matter, exercising its best discretion on how to proceed. with appropriate notice to the D.A.'s insurance fraud unit of the action taken. If the SFC or case referral package is sent only to the D.A.'s insurance fraud unit, it will notify the Fraud Division and determine what action, if any, the Fraud Division desires to take, as indicated in paragraphs (d), (e), and (f) below. The information shall include the suspect's name, carrier or administrator and the claim. (d) As the primary investigative agency in the field of insurance fraud, the Fraud Division will have °first claim" to any SFC or case referral package sent by an insurer for investigation. There can be an exception to this provision if the referring insurer specifically requests that the investigation be done by the D.A.'s office. The Fraud Division will be notified immediately to discuss the situation and avoid any duplication of investigative efforts. (e) If the Fraud Division elects to pursue an investigation of an SFC or case referral package sent by an insurer, the D.A.'s insurance fraud unit will suspend any fiuther action on the case, pending the outcome of the Fraud Division's investigation, and will notify the insurer of this fact in writing. (f) If the Fraud Division elects not to pursue an investigation of an SFC or case referral sent by an insurer, because of excessive caseloads, resource limitations, or any other reason, or chooses to defer any matter referred, the D.A.'s insurance fraud unit will review the referral for investigation. The refemng insurer will be notified of this fact in writing and a copy of the writing will be submitted to the appropriate D.A.'s insurance fraud unit. (g) If the D.A.s insurance fraud unit receives a referral that would be more appropriately handled in another county's jurisdiction, the original receiving D.A.'s office will forward the referral to the appropriate county and notify the Fraud Division. 2 4. Investigations (a) Pursuant to the above provision, and to maximize the expenditure of resources, it is understood and agreed that either party will provide assistance to the other upon request in any investigation where such assistance is needed. This could include serving search warrants, interviewing witnesses, making arrests, etc. (b) Joint investigations, may be undertaken in cases where the parties determine it is beneficial to combine resources to achieve the most efficient and effective results. This will be determined on a case-by-case basis. (c) It is expected that cases will be developed from referrals by insurers, other Iaw enforcementlgovernmental agencies (CHP; EDD; etc.), informants and other responsible sources of information_ Outreach programs are encouraged to promote this aspect of the plan. (d) It is the intent of this joint investigation plan to avoid duplication of investigative efforts by maintaining regular communication to discuss caseloads and share information concerning current investigations. The Fraud Division regional supervisors will meet at a minimum of twice a year with the D.A.'s insurance fraud unit's designee to review the working relationship between both agencies. {e) The deputy district attorney of the D.A.'s insurance fraud unit, or his/her designee, will be available to meet with the Fraud Division investigator at any time during the investigation of a case when so requested by the investigator to discuss any aspect of the case. (f) It is the intent of the parties that by maintaining regular communisation and adhering to agreed upon plans and procedures, the completed investigation will result in the filing of criminal charges and a successful prosecution. At the same time, however, it is understood that not every case that is investigated will result in prosecution. This can happen when the evidence does not develop as expected, material witnesses are no longer available, the case lacks jury appeal, the reasonable likelihood of conviction is minimal, or other unforeseen circumstances develop. The parties will take all possible steps to avoid such situations, as it is not desirable to expend investigative resources on cases that are not prosecuted in court. (g} Any investigative costs associated with a Fraud Division investigation prior to the complaint being filed, the Fraud Division will incur the cost. Any costs associated with the investigation after the complaint is filed, the District Attorney's Office will incur the cost. Responsibility for costs incurred during a "joint" undercover operation will be determined by the Memorandum of Understanding -see section S (c). 3 5. Undercover Operations {a) Both parties recognize the importance of undercover investigations in those cases where it is felt this technique is a viable means (often the only means) of developing evidence to prove a suspected insurance fraud. However, the parties also agree that undercover operations need to be highly organized and carefully monitored by supervisor level personnel to insure the efficiency and integrity of the investigation. It is understood that undercover operations can be very labor intensive and time consuming, and don't always produce the desired results. (b) Either party may decide to conduct an undercover operation in a particular case using its own personnel and resources. In a situation where the Fraud Division conducts its own independent undercover investigation in Butte County, the D.A.'s insurance fraud unit will be available to provide any advice or other assistance requested. (c) In a case where there will be a "joint° undercover investigation, there will be a memorandum of understanding (M.O.U.) prepared prior to the start of the investigation, which outlines and specifies the goals and the objectives of the investigation, as well as the duties and responsibilities, including personnel and financial responsibilities, of each of the parties in the investigation. 6. Case Filing Requirements (a} The investigation of suspected insurance fraud cases should focus not only on the development of probable cause to make an arrest, but also on the obtaining of sufficient evidence to prove the charge beyond a reasonable doubt in a criminal court. It is understood that each case is unique, and that certain action may need to be taken in one case that would not be taken in another. (b) When submitting a case for prosecution, the investigator should present as complete a package as possible, including a detailed report, which outlines the offenses alleged to have been committed, the details of the investigation, and the evidence available to prove the charges, including identification of available witnesses and supporting documentation. In cases involving alleged false statements of misrepresentations, there must also be identified evidence to show materiality of the alleged false statement or misrepresentation to the claim. (c) To promote efficiency in this area, Fraud Division investigators are encouraged to contact the Butte County D.A. early in the investigation of a case to share ideas and develop strategies that will lead to a prosecutable case. (d) The D.A. will ensure that all formal case presentations made by the Fraud Division will be reviewed within ten working days of the presentation or delivery. If additional investigation is believed to be needed by the reviewing D.A., helshe will notify the case investigator immediately. The case investigator will complete 4 the additional investigation as soon as reasonably possible and provide the D.A. with status updates at a minimum of every fiR~en working days until the investigation is completed. The D.A. will fiarther ensure that decisions on complaint filings shall be done in a timely fashion but no longer than thirty days from the date of receipt. If a formal case is rejected for prosecution, the D.A. will prepare a letter in writing stating the reasons for the rejection and provide the letter to the case investigator within ten working days following the rejection. 7. Training (a) Both parties have been, and will continue to be, active participants in the annual CDAA/CDI insurance fraud training seminar. This will provide a significant portion of the ongoing training of both parties in the area of insurance fraud. (b) The parties will participate in joint informal training sessions as necessary on issues important to the investigation and prosecution of insurance fraud cases. (c) The parties will assist each other, when requested, in training sessions for insurance carriers and administrators, or issues important to the detecting, investigation, and prosecution of insurance fraud cases. Both parties will notify each other when there is a request for training by an insurance carrier and administrator. 8. Problem Resolution (a) It is the intent of this joint plan that any problems or differences that may arise between the parties be resolved quickly through early, direct, and open communication by those personnel directly involved in the dispute. If necessary, the Chief Investigator of the Fraud Division and the prosecutor in charge of the D.A.'s insurance fraud program may be called upon to resolve any dispute, concentrating on the best interests of the overall insurance fraud program. 4e.-c_ ~ 3~ p ~ Edward J. Szendr y Date Chief Investigator Butte County District Attorney ~.~ 9 _ athryn L. Scholz Date Chief Investigator, Fraud Division California Department of Insurance