Jerry Hay was a salesman and president of Jerry Hay, Inc., an insurance consulting firm. For several years before 1969, Jerry Hay provided insurance services for William Stone, the vice-president and executive officer of Quality Furniture. Through this contact, Jerry Hay solicited and obtained Quality Furnitures business. Immediately thereafter, on November 10, 1969, Jerry Hay, Inc., procured fire insurance for Quality Furnitures three warehouses and three stores.
