VERBAL STATEMENTS USELESS WITHOUT WITNESSES TO TESTIFY ON ITS VERACITY
Dear Mr. Liu: While waiting for your response on the THIRTY-FOUR (34) COUNTS OF BAD FAITH EVIDENCES dated July 31, 2020, PLEASE SEE, PAR. 3 DENIAL LETTER dated July 31, 2020You wrote,"Attached is a copy of the photo media sheet with the photographs obtained during our virtual Claims Xperience inspection which took place on May 5, 2020. The information provided by John Titouah was provided verbally and not in a written form. The information contained in our claim file notes are not considered claim-related documents, as defined by Insurance Code Section 10082.3 and will not be provided."You wrote, " The information provided by John Titouah was provided verbally and not in a written form. " COMMENTS : This means that the information provided by John Titouah to you are in uttered words and sentences or through verbal communications. How would you prove that what you are writing to me about matters on the May 5, 2020 incident which led you to determine denial of our claim is exactly what he said, no more, no less. You may need to present a third party, credible non interested person who is present in the conversation to attest to the veracity and correctness of those information and swear that those are based exactly and actually on what the informant said. Failure on your part to present such a third party credible witness to attest to the veracity of your statements, whether it precisely conform to what Totouah exactly and actually said, and this failure would definitely turn all your denial letters from May 6, 2020 to July 31, 2020 to shambles, naught and worthless. Consequently, this becomes a manifestation that you have not written any denial letter at all from May 6, 2020 to July 31, 2020 and therefore lead to the conclusion that you did not diligently act on our claim in due time and be considered as another violation of the implied covenant of good faith and fair dealing between us. Please acknowledge receipt of this e-mail and kindly inform me when do I expect a reply to this email. Yours faithfully, Antonio L. Buensuceso |
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