Page 107 - Bundle for MF Final

Bates no 106

6. EARLIER MISREPRESENTATIONS
Mr Solheim had been less than honest in many of his communications with Kingsley Napley,
MJC and his insurers. Text highlighted in red indicates a probable misrepresentation.
Schedule: Repeated between January 2017 to February 2018:
The following statement was repeated on various documents, leading to the final claim
schedule;

"For the avoidance of doubt and in the spirit of openness, the claimant has received
insurance payments. Lump sum payments had been made for the loss of his licence,
but on the policies for which he himself paid. These are therefore irrelevant to the
claim. He has also received income replacement insurance that the policy required
him to make a subrogated claim on behalf of the insurer. The claimant is therefore for
its full loss."

Complex and policies and claims have not been produced.

Premiums paid by Loss of licence Personal accident Income replacement

Paid by himself 1 Hiscox 2 3 Cirencester
Declared None known Declared
False application? But possible Subrogation rights
Possibly duplicative of t(oewe1tAIY' Duplicative of 5 & 8?
4
Excess policy to 4
Paid by easyJet 4 easyJet package 5 AIG 6
Possibly duplicative Not declared Not applicable
with 1 Not disclosed by EJ
Duplicative with 8
Third party 7 8 Diamond 9
Diamond insurance Not applicable Probably duplicative Not applicable
with 5

This implies that:
• policie� that resulted in lump sum paymenti for loss of licence for which Mr Solheim
(himself had) paid as well as

• an income replacement policy which requires him to make a subrogated claim on
behalf of the insurer

have no effect on - and do not mitigate or duplicate - his claim against Diamond Insurance.
The declaration omits all mention of the AIG personal accident policy. This appears to have
5
been included as a company-wide employee benefit financed by easyJet and not paid for by
Mr Solheim, himself. It appears that Mr Solheim did not realise he had personal accident
cover until October 2016 after his licence had been suspended for the second time. EJ and
JLT see

Q)
00
ro
Cl..