LUPARDUS VS HOMESITE INDEMNITY CO - CASE 22CV6485 | HOMESITE VS LUPARDUS - CASE 22CV6473

829 Creekside Drive

Gardner, KS 66030
(913) 912 2255
LUPARDUSVSHOMESITE@GMAIL.COM
HOMESITE@THELUPARDUSCORP.COM

Mediation vs Litigation Request - 1/18/23

Jan 18, 2023

Dear Micheal Baumberger , HOMESITE INDEMNTY / AMERICAN FAMILY INSURANCE

I make this request to Homesite Insurance/American Family Insurance via

your chosen legal representation Mr. Michael Baumberger, esq to request

that we mediate the disagreements pertaining to claims 01-003-433432,

01-003-892630, 01-003-926870, 01-004-108972, 01-004-261602,

01-005-372763 and 01-005-577940. Mr. LuPardus agrees that claim no.

01-003-740242 and 01-003-982721 were paid in accordance with the policy

terms and agree no further action is needed on either of these two

claims. Mr. LuPardus does however wish to acknowledge that while claim

01-004-117366 was paid in August 2022, he would still like to discuss

the material fact of the extreme delay and any potential violation(s) of

K.A.R. 40-1-34 with the claim, having submitted the claim in December

2021, receiving information that the claim was closed in June 2022 via a

Letter of Experience request made to the Insurer, and was not

reported/paid to Mr. LuPardus until late August 2022. Mr. LuPardus is

willing to delay his current suit against Homesite/American Family, and

is willing to forgo any future suit(s) Mr. LuPardus has against Homesite

Insurance if mediation between the parties is successful. Mr. LuPardus

also has no issue mediating with Homesite Insurance/American Family

Clerk of the District Court, Johnson County Kansas

1/23/2023 11:02:26 VR
Insurance’s attorney Mr. Michael Baumberger directly instead of any

representative employed at Homesite Insurance/American Family Insurance,

if Mr. Baumberger is granted the authority to negotiate and settle the

claim(s) listed and any/all disagreements of material facts related to

the claims can be resolved.

Homesite Insurance and American Family Insurance should accept a request

to mediate from its insured Mr. Lonnie LuPardus for several reasons:

First, mediation is often a faster and cheaper alternative to litigating

a dispute. It eliminates the time spent waiting for a trial and an

appeal. Second, mediation is a voluntary, confidential process in which

both parties attempt to resolve their dispute with the help of a neutral

third party. It allows the parties to maintain control over the outcome

of their dispute, and it provides a risk-free environment, as neither

party can be forced to accept an agreement. Finally, mediation is a

great alternative to litigation since it allows the parties to craft

their own solution to their disagreement, which may not be available in

court.

I, Lonnie LuPardus, Insured with Homesite Insurance hope you will accept

this request to mediate the disagreements we have, and hope to resolve

these issues quickly, efficiently, and fairly.

/s/ Lonnie LuPardus, Pro Se.

Clerk of the District Court, Johnson County Kansas

1/23/2023 11:02:26 VR