Page 135 - Bundle for MF Final

Bates no 134

APPLICATION FOR ASSISTANCE OF A M KENZIE FRIEND
c
PART S:CHRONOLOGY OF INSURANCE CLAIMS
'Thanks for the chat yesterday. It is very uncertain and frustrating time right now. I
have read through the details on the base pages regarding Joss of licence. The
process looks pretty clear to me and is the policy covered fully by easyJet?.

"Where will I find information about personal accidt cover which is supposed to
be four times salary as mentioned in the contract".

On 25th January 2016 Ms Clarke responded that "HR have indicated you probably
would qualify for personal accident cover".

59. qn 11th February 2016 Kingsley Napley's work records state:

"Speaking about SS's insurance polici explaining that th r
advise on, and that I cannot give any advice without seei !ides. He will
get both policies sent to me4 . He thinks that he cannot c im on � s of licence as at
°
the moment he has not lost his licence permanently. Re -tn
policy - he didn't even know that he had it, although he has been paying it on direct ... �I
debit. He is making investigations and should have an answer next week''.
vew�t/1'
In fact. the Claimant had four relevant policies: not two. f,
ftf r,JDt rJ
1
5.10 SCHEDULE OF LOSS: 18 FEBRUARY 2016 f
TH
th
60. On 18 February 2016. the Claimant agreed the sworn SCHEDULE OF LOSS which omits
the AIG policy. This was technically correct. because at that time his employment had not
been terminated. However, the Claimant knew that he would be leaving easyJet within
weeks and that the AIG policy was highly relevant.

61. The AIG policy provided cover for legal fees and not reporting it to Kingsley Napley was
clearly a conscious decision. Rather than disclose the AIG policy he paid £95,840.06 in
legal fees that he could have recovered.

th
th
62. Between 4 August 2014 and 8 March 2018, the Claimant certified the accuracy at least
four iterations of the SCHEDULE OF CLAIM. Paragraph 7 of each states:
41
"For the avoidance of doubt and in the spirit of openness, the Claimant has received
insurance payments. Lump sums have been made for the loss of his licence, but
under policies for which he himself has paid. They are therefore irrelevant to this
claim"

This certification is false because:

• The AIG policy is for personal accidents and not for loss of licence 42 ;
• The Claimant did not pay the premiums in respect of it: easy Jet did.

39 The policies referred to are the Hiscox loss of licence and the Cirencester Friendly income protection policy. The
AIG policy was not disclosed
4 o He had at least four
41 4th August 2014 through to March 2018
42 The Claimant recognised the difference
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