FROM THE DESK OF CHRISTOPHER KING, J.D.

Arlington Compliance
617.543.8085
kingcast955@icloud.com

Re: Total Loss Insurance Claim of [Vintage BMW Enthusiast] on 1983 BMW 528e

Dear [Unfair Unreasonable Claims Adjuster]

It has come to my attention that a fellow vintage BMW colleague of mine is not
receiving a reasonable replacement value for his 1983 E28 model BMW 528e.
Given the current market for these cars I find your offers to be issued in Bad Faith.

I am a vintage SAAB and BMW enthusiast who prides himself on staying up on the
market of these vehicles. I have owned twelve mostly vintage SAABs and eight BMWs
some vintage and some not vintage at the time I bought them but vintage now. My
daily driver is a 1988 535is -- the high-performance model of Mr. Mendez’ car. It is
worth a bit more than his car would be worth but as you will see Mr. Enthusiast has
only provided his exact model for comparables so he is coming in Good Faith but I
don’t believe that you are.

My background and experience is not only based on the 30+ cars I have owned, there
are yet another 15 motorcycles involved and there have been several total loss
situations in both genres. Each time I obtained a fair result in my insurance Claims.

With such in mind, I will assume arguendo that you are aware of what the vehicle is
and the fact that it basically defined BMW in the United States as a manufacturer of
premier sport-luxury sedans. The model basically ran through the very influential
1980’s along with the E30 model, its smaller sibling.

These models, in particular the E30, have made substantial gains in the marketplace
over the past several years, and this is true in every state. Mr. Enthsiast informs me
that his car is registered in Kansas rather than California so there is a small fluctuation
owed there certainly but the prices you are giving him as a total are not reflective of a
Good Faith Claim resolution.

Furthermore these cars are increasingly sold to a global U.S. Market, with buyers
finding them on Bring a Trailer, Cars and Bids and SearchAllCraiglist, so I’m afraid with
classic cars like these that are nearing relative extinction your regional argument does
not impress me. Furthermore, prices have risen dramatically over the past 2-3 years so
the $5K car in this cars and bids link would honestly be worth about twice that now,
and as you can see the white car sold this year went out at just under $10K.
https://carsandbids.com/search/bmw/528e

https://bringatrailer.com/listing/1985-bmw-528e-11/

https://bringatrailer.com/listing/1982-bmw-528e-6/

https://bringatrailer.com/listing/1982-bmw-528e/

1
 FROM THE DESK OF CHRISTOPHER KING, J.D.
Arlington Compliance
617.543.8085
kingcast955@icloud.com

https://bringatrailer.com/listing/1988-bmw-528e-26/

https://bringatrailer.com/listing/1987-bmw-528e-11/

https://bringatrailer.com/listing/1988-bmw-528e-25/

https://losangeles.craigslist.org/lac/cto/d/burbank-1988-bmw-528e-
automatic/7516588914.html

https://inlandempire.craigslist.org/ctd/d/perris-1984-bmw-533i-speed-manual-
clean/7524593635.html

https://portland.craigslist.org/mlt/cto/d/portland-1988-bmw-528e/7522793976.html

https://annapolis.craigslist.org/cto/d/edgewater-bmw-auto-silver-e28/7519696782.html

https://www.hemmings.com/classifieds/cars-for-sale/bmw/528e/2508286.html

https://www.autotrader.com/cars-for-
sale/vehicledetails.xhtml?listingId=654828817&makeCodeList=BMW&modelCodeList=528E
&city=Mission%20Viejo&state=CA&zip=92691&location=&searchRadius=0&isNewSearch=f
alse&marketExtension=include&showAccelerateBanner=false&sortBy=relevance&numRecor
ds=25&dma=&listingTypes=USED&referrer=%2Fcars-for-
sale%2Fbmw%2F528e%2Fmission-viejo-ca-
92691%3Fdma%3D%26searchRadius%3D0%26location%3D%26isNewSearch%3Dfalse%26mar
ketExtension%3Dinclude%26showAccelerateBanner%3Dfalse%26sortBy%3Drelevance%26num
Records%3D25&clickType=listing

********

If you review these postings you will find that you offered him roughly the same as the
lowest of the low end, nothing in the mean or median whatsoever, and to me that is
simply not fair. See generally Wilson v. 21st Century (Nov. 29, 2007, S141790) noting that
you are required to have a Genuine Dispute in hand to deny coverage; in this instance such
a Good Faith Defense has not been demonstrated.

Mr. Enthusiast is being fully transparent in the sense that he will tell you up front he is going
to buy his car back at salvage value and rebuild his car; but such fact does not obviate your
responsibility to fully compensate him for it in the first place.

As such, he is willing to accept less than top dollar for the vehicle that some of the comps
are getting but at the rate you are offering him I believe he has a Bad Faith Claim against
your company; a consideration he will willing to set aside for a figure much closer to the
$7,500.00 that most people are getting for these cars.

2
 FROM THE DESK OF CHRISTOPHER KING, J.D.
Arlington Compliance
617.543.8085
kingcast955@icloud.com

As Mr. Enthusiast is delivering this letter to you by his own hand you may assume that I have
full authority to discuss matters on his behalf but I prefer to do so only with him present on
any and all calls or zoom conferences.

We can arrange that largely at his and your convenience as I work from home and am
somewhat flexible.

Please advise.

_______________________
Christopher King, J.D.

DISCLAIMER:

I am not legal Counsel to Mr. Enthusiast nor am I a practicing Attorney and I don’t care to be that or do that
anymore. I have a network of referral Attorneys for that. I am a consumer advocate, investigative journalist and
Hollywood screenwriter reaching out to you on behalf of a community friend and trying to negotiate a dispute in
Good Faith.