COMPLAINT AFFIDAVIT VS. JOHN TITOUAH DATE EXECUTED 17JUNE20

COMPLAINT AFFIDAVIT     ANTONIO L. BUENSUCESO                                        (  PLAINTIFF)                                         -VS-   JOHN TITOUAH             ( DEFENDANT )                                                                              AFFIDAVIT PREFATORY STATEMENT JOHN TITOUAH,  BOLD AND DARING WITH AN ASSUMED CLOUT OF IMPUNITY IN DOING FRAUD, AND AN EVIL INTENT  TO ACQUIRE AN EXPECTED HUGE MONETARY GAIN FOR HIMSELF,  BUT A RECIPROCAL GREAT FINANCIAL LOSS TO US, WHILE ABUSING THE TRUST AND CONFIDENCE WE BESTOWED UPON HIM,  RIGHT HERE AND THERE, ON MAY 5, 2020 DELIBERATELY AND INTENTIONALLY AND TREACHEROUSLY AND FELONIOUSLY COMMITTED AN ACT TANTAMOUNT TO VANDALISM ON OUR PROPERTY BY WAY OF AN ENLARGED EXCAVATION IN EXCESS OF WHAT IS NEEDED TO FIX THE LEAKING HOT WATER VERTICAL PIPE, EMBEDDED IN THE SLAB UTILIZING A HUGE JACKHAMMER THAT DAMAGED HOT AND COLD WATER PIPES IN THE SLAB ADJACENT TO IT,  THEN, STAGED A RIGGED, FALSIFIED, UNTRUE  AND FRAUDULENT LIVE VIDEO MESSAGE "NO LEAK IN THE SLAB BUT SUSPECTED LEAK UNDER THE FOUNDATION" SCENARIO SHOWING A DRY EXCAVATION MADE OUT OF VANDALISM AND REPORTING THIS RIGGED AND FRAUDULENT PRESENTATION THROUGH HIS CELL PHONE TO THE PERSON/S ON THE OTHER SIDE OF THE PHONE RESULTING TO THE DENIAL OF OUR INSURANCE CLAIM FROM STATE FARM AND AMONG OTHER CONSEQUENTIAL DAMAGES CONNECTED TO IT. SWORN STATEMENT I, ANTONIO L. BUENSUCESO JR., 65 YEARS OLD, AN INDIGENT LITIGANT, A RECIPIENT OF FOOD STAMPS AND HELP FROM MY FAMILY WITH ADDRESS 10620 CAMINITO DERECHO, SAN DIEGO CA 92126 MAKE AN OATH AND DO SOLEMNLY SWEAR TO GOD AND TO THE PEOPLE OF THE UNITED STATES OF AMERICA CONVEY THAT THE FOLLOWING STATEMENTS, VIDEOS AND PICTURES LABELS AND CAPTIONS THEREWITH ARE ACCORDING TO MY DIRECT PERSONAL EXPERIENCES AND ARE TRUE TO THE BEST OF MY KNOWLEDGE AND BELIEF. SO HELP ME GOD: (SEE PICTURE E   EVIDENCE OF BEING A FOOD STAMP RECIPIENT) A. I SHOW INFORMATIONS I RELIED UPON FOR ME TO BE CONSIDERED AS AN EXPERT WITNESS ON MAINTENANCE AND OPERATION OF OUR HOUSE HOT AND COLD WATER SYSTEMS IN PARTICULAR:  (SEE 1b. EXPERT WITNESS EXPLANATION) 1. I completed courses, as evaluated by Educational Records Evaluation Service, Sacramento, California, one (1) year undergraduate study in the field of Automotive Mechanics, one(1) year undergraduate study in the field of Diesel Mechanics and a Bachelors Degree in Management Engineering.   (SEE 2. EDUCATIONAL CREDENTIALS) 2. I have work experience and technical and engineering background in the field of operations and maintenance  in SHELL REFINERY,  a 110,000 barrels per day petroleum refinery in Tabangao, Batangas City, Philippines of PILIPINAS SHELL PETROLEUM CORPORATION from 1978 to 2003. A 25-year solid operations and maintenance in a petroleum refinery experience.  (SEE 3a. EVIDENCE OF EMPLOYMENT 3. I have technical experience in the field of operation and maintenance of a biodiesel plant in New Leaf Biofuel,  2285 Newton Ave, San Diego CA 92113. A two-year local operation and maintenance experience of a bio-diesel manufacturing plant close to downtown San Diego. (SEE 3b/3c.. LETTERS OF RECOMMENDATION FROM TYLER CASE and PORTIA SMITH, EVIDENCE OF EMPLOYMENT) B. NARRATIONS OF EVENTS AND COMMENTS RELATED TO THE COMPLAINT 4. Our house in address 10620 Caminito Derecho, San Diego, CA 92126 is protected by FIRST AMERICAN HOME WARRANTY under policy CONTRACT # :10496493504 and STATE FARM HOME INSURANCE under policy NUMBER 77-C3-B499-7. 5. Our house in address 10620 Caminito Derecho, San Diego, CA 92126 had a slab leak noticed on 26 April 2020, a Sunday. 6. On 27 April 2020, Monday,  early morning,  we reported the incident to FIRST AMERICAN HOME WARRANTY and STATE FARM HOME INSURANCE, respectively. 7. On part of the FIRST AMERICAN they sent to us JOHN TITOUAH, a plumber from ALL EXPRESS PLUMBING with business address at 107 E 7th Ave, ESCONDIDO, SAN DIEGO CA 92025 with telephone no. (760) 420-9997, for slab leak repair. 8. On part of the STATE FARM they sent to us QUICK- DRY FLOOD SERVICES with business address at 2350 Meyers Ave, Escondido, CA 92029 with telephone nos : (760) 744-2212, 753-8811 and Fax : 744-2890, for drying up operations. 9. We hired the services of both contractors that Monday 27 April 2020.      10. We hired the plumber, JOHN, ALL EXPRESS PLUMBING, who FIRST WARRANTY sent to us,  whom I trusted and confidently relied upon to fix our hot water line leak as he had stressed to us at least  a couple of times  that he worked for the homeowners and not for the insurance companies. Hence, I feel confident that he will render the best he could do for us. 11.  On  April 30, 2020 John Titouah came by himself and did a leak detection using leak detection instrument to know where the leak/leaks was/were. It is to our belief John being a licensed plumber and endorsed to us by FIRST AMERICAN HOME WARRANTY  that he knew where the leak is located and and how to fix it. 12. We requested for a copy his leak detection report submitted to the FIRST AMERICAN HOME WARRANTY. John refused to give us any despite of our earnest PERSISTENT request. This fact raised a red flag, his response bothered me somehow.  13. We requested for the same copy from FIRST AMERICAN  twice, but they refused to give us one.  Likewise, this raised a warning that there might be some insidious agreement between them against to our interest. 14. Nevertheless, John and we,  discussed options on how to repair the leak:       a. Option 1 is to repair the leak and he will be paid $700 covered by insurer FIRST AMERICAN. NO COST TO US.       b. Option 2 is to install new pipe out of the slab  to replace the leaking pipe embedded in the slab. He advised us that this is a better option because it is easier to know, and see a leak and repair it if the same happened again in the future. However, we need to pay him an out from our pocket $3600 in addition to the amounts we could recover from FIRST AMERICAN up to $1500. In other words, he would take home a hefty more or less $5100.  15. We agreed to do Option 1 since it is no cost to us as the expense of $700 is well covered by our policy. 16. From May 1, 2020 onwards to May 4, 2020, we tried to reach him in those four (4)days but in vain and we just left a question message for him when he will be coming back. 17. On May 5, 2020 about 3:00 pm with OPTION 1 IN OUR MIND, John, the plumber, came with 2 helpers with a big jackhammer.  BUT without showing any pipe, connectors, torch, butane or map gas or soldering materials. (see PICTURE C MATERIALS AND TOOLS HE DID NOT SHOW up WITH HIM) 17A.  AFTER THOROUGH STUDY AND ANALYSIS OF THE EVENTS UNFOLDED IN THIS INCIDENT I BELIEVE THIS IS A MANIFESTATION  THAT HE SHOWED UP NOT TO ACTUALLY FIX THE LEAK BUT FOR ANOTHER TREACHEROUS AND MALICIOUS PERSONAL OBJECTIVE : TO DIG AN EXCAVATION EXPOSING NO LEAK IN THE SLAB BUT A PRESUMED LEAK UNDER THE FOUNDATION IN A MANNER TANTAMOUNT TO VANDALISM WITH A COVERT PURPOSE PRIMARILY FAVORABLE FOR STATE FARM HOME INSURANCE AS THIS "DRY EXCAVATED CONCRETE SLAB" SERVES AS A PROOF OF A LEGAL ALIBI FOR THEM TO DENY OUR CLAIM FOR SECONDARY DAMAGES. 17B. IN MY AFTERTHOUGHT THESE QUESTIONS LINGERS ON MY MIND, WHAT A DISPLAY OF BRUTE FORCE FOR A WORK WORTH $700,  HOW COULD HE PAY HIS HELPERS? HOW MUCH MONEY LEFT FOR HIM AND HIS BUSINESS TO SURVIVE? 17C. ASSUMING HE RELIED AND BELIEVED ABSOLUTELY ON THE HEAT SIGNATURES DETECTED BY HIS INSTRUMENT AND HE KNEW EXACTLY WHERE THE LEAK IS AND ABSOLUTELY BELIEVED THAT HIS FINDINGS ARE ACCURATE, THEN HE FULLY KNEW WELL THAT THE LEAK IS UNDER THE FOUNDATION, THAT IN SUCH DEPTH OF THICKNESS OF HARD CONCRETE HE WOULD NOT BE ABLE TO EXCAVATE AND HAVE ACCESS TO THE LEAKING PIPE,  IF HIS INSTRUMENT SAID SO,  WHY THEN HE ENTERED INTO AN AGREEMENT WITH US TO FIX THAT LEAK WHEN HE SHOULD HAVE DECLINED THAT WORK, BECAUSE, ACCORDING TO HIM, FIRST AMERICAN WOULD NOT ALLOW HIM TO DIG MORE THAN TEN (10) INCHES, AND SHOULD  NOT HAD SHOWED UP AT ALL AND LET US LOOK FOR A PLUMBER WHO COULD DO THIS WORK FOR US. 17D. JOHN TITOUAH DID A JOB HE IS NOT AUTHORIZED TO DO. HE IS AUTHORIZED TO "Access pipe encased in concrete slab and repair pipe." HE IS NOT AUTHORIZED TO MAKE AN EXCAVATION TO SEARCH FOR LEAK ANYMORE BECAUSE HE HAD ALREADY PERFORMED A LEAK DETECTION TEST TO DETERMINE WHERE EXACTLY IS THE PIPE BREAK ON APRIL 30, 2020. THE IMAGE PICTURE F1 SHOWED THE WORK WHICH SHOULD HAVE DONE BY TITOUAH WHICH SHOWED THAT TITOUAH DID A WORK HE IS NOT AUTHORIZED TO DO.  PICTURE F1 ENLARGED WEDNESDAY, MAY 6, 2020 MESSAGE FROM FIRST AMERICAN HOME WARRANTY SAYING THE CORRECTION TO THE PROBLEM  IS TO ACCESS PIPE ENCASED IN CONCRETE SLAB AND REPAIR PIPE AND NOT TO EXCAVATE LEAKING PIPE UNDER THE FOUNDATION.  THOUGH I HAVE NOT SEEN  JOHN TITOUAH, THE PLUMBER,  REPORT ON WHERE THE LEAK IS,  BY VIRTUE OF THIS MESSAGE, IT CAN BE INFERRED WITH 100%ACCURACY THAT THE LEAK IS NOT UNDER THE FOUNDATION BUT IN THE PIPE ENCASED IN THE SLAB AS INFORMED AND INSTRUCTED AND ADVISED BY FIRST AMERICAN. 18. GOOD THAT WE TOOK VIDEOS AND PICTURES OF THIS INCIDENT. THOUGH JOHN TITOUAH KNEW FULLY WELL THAT WE ARE TAKING VIDEOS ON HOW HE IS CONDUCTING THIS LEAK REPAIR  HE WAS STILL SO BOLD AND DARING AND ACTING LIKE HAVING AN ASSUMED CLOUT OF IMPUNITY IN DOING HIS FRAUDULENT ACT. 19. Where JOHN TITOUAH could do it by himself based on my working experience, using handy electric rotary hammer and drill and chisel tool without any helper and that brutal jackhammer. (SEE THE WATER LEAK SPOT BEFORE DIGGING IT OUT IT IS SOFT LIKE A PIECE OF CAKE, SEE PICTURE B). This fact about the leaking spot which John INTENTIONALLY did not disclose and deliberately and fraudulently  and deceptively hide from us, had been revealed to us in VIDEO 6 as the leak deteriorated a couple of weeks after. 19A. LEAK SHOWN IN VIDEO 6 HAS BEEN COLLABORATED BY FIRST AMERICAN THROUGH A MESSAGE IN THEIR MESSAGE CENTER SITE WHICH EFFECTIVELY CONVEY THE  FOLLOWING: LEAKING PIPE ENCASED IN THE SLAB NOT LEAKING PIPE UNDER THE FOUNDATION WEDNESDAY, MAY 6, 2020 MESSAGE FROM FIRST AMERICAN THAT ALL EXPRESS PLUMBING IS AUTHORIZED TO COMPLETE THE FOLLOWING REPAIRS. FAILURE, LEAKING WATER UNDERNEATH DINING ROOM HALLWAY WHICH WILL BE CORRECTED THIS WAY:  ACCESS PIPE ENCASED IN A CONCRETE SLAB AND REPAIR PIPE.  JUST A SIMPLE PIPE LEAK REPAIR AND JUST NEED A DELICATE MINUTE EXCAVATION NOT THE EXTENT WHERE THE CONCRETE SLAB, OUR PROPERTY WAS RUINED TO A POINT WHERE ALL THE PIPES ENCASED IN THE SLAB HAVE BEEN SUBJECTED TO TREMORS AND STRAINS AND STRESSES  AND IMPENDING LEAKS BY THE RECKLESS USE OF THE JACKHAMMER BY JOHN TITOUAH, WHICH IN OTHER WORDS, IS TANTAMOUNT TO VANDALISM. (SEE PICTURE F AND PICTURE F1.) 20. When John and his two helpers have dug the leaking spot, I noticed they are looking traces where the leak is showing up. They could not find any.  I asked John whether the valve to the water heater is full way open. He answered, "It's not my house", I told him,  "I'll check on it. "OK lets check it together", he replied. We went to the water heater. He gestured opening up the valve and asked if the valve as I see it,  is fully opened.   I replied, "Let me check". I checked and pretended to agree with him but actually the valve was just slightly opened. I knew how it feels when a valve is fully open or not,  being a SHELL petroleum REFINERY operations and maintenance man for 25 years.(seeVIDEO 3) 21. John with his two helpers excavated the affected area with a jackhammer then when the leak seems to be appearing on the line the plumber, John,  stopped digging and appeared to be bothered, (see VIDEO 4) he instructed his helper to open the the kitchen hot water faucet (see VIDEO 5), purposely to release pressure on the line, then, the leak disappeared and is consistent with my experience when pipes and vessels are to be depressurized we do it by expelling pressure out by opening the valve attached to it to the atmosphere as in opening the hot side of the kitchen faucet in this case and he continued digging but farther away from that leaking point.   (see VIDEO 8 and PICTURE 1A) 22. John and his two helpers after digging almost 1.5 square foot of concrete with a depth of 6 inches while the hot water line is devoid of pressure he set his camera, took a live video of the excavation and informed the man on the other side of the line, whom I did know at that time who he was, that he can not find a leak THOUGH HE HAD DUG 10 INCHES OF CONCRETE, (absolute lie),  though he just dug 6 inches at the most (see VIDEOS VIDEO 1, VIDEO 2 , VIDEO 6 and PICTURE 1, PICTURE 2, PICTURE 3, PICTURE A) and concluded a statement that the leak is under the foundation.  23. Later in the afternoon of that same day,  May 5, 2020, the STATE FARM insurance adjuster talked to us (now we know who was the man on the other side of the line) that based on the plumbers video footage and statements BY JOHN, our claim for secondary damage is not covered because the leak is under the foundation. 24. Earlier in the afternoon, in that same day, May 5, 2020  John also called up PROBABLY the American Home Warranty after STATE FARM and showed the same excavation FOOTAGE with no trace of leak but a suspected leak under the foundation, that he could not dig anymore; hence, he made it appeared that he was allowed repair work, OPTION 2, the more expensive project of rerouting the pipe out of the slab.  25.  The following day, May 6, 2020,  in the afternoon John   came back presumably to do a re route of the leaking hot water line. We talked and told him that our claim for secondary damages from STATE FARM has been denied on account of his falsified video footage and statements. I told him, "You can go." We fired him FOR HIS FRAUDULENT ACT. 26. As I analyzed the events unfolded on May 5, 2020, John worked abusing our trust and confidence like a secret agent helping  STATE FARM INSURANCE out of liability which we suspect that he will be paid for it to recover his costs and be awarded sumptuous considerations for his craft and ingenuity;   27.  and John tried to mislead the FIRST AMERICAN HOME WARRANTY into allowing him do OPTION 2, a more costly re route of hot water line. A hefty $5100 project worth instead of just $700. 28.  By the reckless using of the jackhammer which is tantamount to an act of vandalism, John damaged other pipes, probably the cold water pipe in the slab along the hallway and/or the cold and hot water pipes embedded in the slab adjacent to it towards the kitchen sink that subjected those pipes to an impending leak in the days to come as constant dampness has been noticeable in that spot now. (see VIDEO 7 and SUPPORTING LEGAL ARTICLES      1a. VANDALISM EXPLANATION) 29. John got an expectedly huge financial gain out of this fraud for himself and a supposed  great loss to us being denied of insurance coverage payment from STATE FARM in an estimated $10,000 to $15000 minimum depending on how much Quick-Dry Flood Services charged us and  the restoration company do it and $3600 for OPTION 2 pipe leak repair from our pocket. 30.  As a matter of fact :The following day we received a denial of our claim for secondary damage by STATE FARM (see STATE FARM DENIAL LETTER below). 31.   HIS FRAUD EVENTUALLY  EXPOSED ITSELF.  After a couple of weeks, May 20, 2020, the leak deteriorated while opening and closing the valve to the water heater to take shower and it showed up not under the foundation as John stated (see VIDEO 6) but a leak in the slab which JOHN intentionally and deliberately hide from us; a leak which is most easily visible with a naked eye which can be repaired less costly $700 when not vandalized and not a leak under the foundation which JOHN TITOUAH deceptively and fraudulently stated. 32. JOHN TITOUAH,  BOLD AND DARING WITH AN ASSUMED CLOUT OF IMPUNITY IN DOING FRAUD, AND AN EVIL INTENT  TO ACQUIRE AN EXPECTED HUGE MONETARY GAIN FOR HIMSELF,  BUT A GREAT FINANCIAL LOSS TO US, WHILE ABUSING THE TRUST AND CONFIDENCE WE BESTOWED UPON HIM,  RIGHT HERE AND THERE, DELIBERATELY AND INTENTIONALLY FELONIOUSLY COMMITTED VANDALISM ON OUR PROPERTY BY WAY OF AN ENLARGED EXCAVATION IN EXCESS OF WHAT IS NEEDED TO FIX THE LEAKING PIPE, UTILIZING A HUGE JACKHAMMER THAT DAMAGED HOT AND COLD WATER PIPES IN THE SLAB ADJACENT TO IT,  THEN, STAGED A RIGGED, FALSIFIED, UNTRUE  AND FRAUDULENT LIVE VIDEO MESSAGE "NO LEAK IN THE SLAB BUT SUSPECTED LEAK UNDER THE FOUNDATION" SCENARIO SHOWING A DRY EXCAVATION MADE OUT OF VANDALISM THROUGH HIS CELL PHONE TO THE PERSON/S ON THE OTHER SIDE OF THE PHONE. 33.   AS I SEE IT, HE HAD THE CAPACITY TO WILLFULLY, INTENTIONALLY DEFRAUD EITHER THE INSURANCE COMPANIES OR THE HOMEOWNERS OR BOTH FOR MONETARY GAIN. I STRONGLY BELIEVE HIS FRAUD MUST BE STOPPED TO MAKE OUR COMMUNITIES SAFER. 34. IT IS TO MY BEHOLDEN BELIEF THIS A CRIME NEEDED TO BE REPORTED TO THE POLICE AND MERIT POLICE ACTION AND BE PURSUED WITH SUPERFLUOUS TENACITY TO DETER THIS PLUMBER, JOHN TITOUAH DOING THIS FRAUDULENT ACTS AGAIN FOR THE SAKE  OF JUSTICE, FAIRNESS, SAFETY AND SECURITY IN OUR COMMUNITY. Yours faithfully, Antonio L. Buensuceso 1. SUPPORTING LEGAL ARTICLES 1a.VANDALISM EXPLANATION California Code, Penal Code - PEN § 594 (a) Every person who maliciously commits any of the following acts with respect to any real or personal property not his or her own, in cases other than those specified by state law, is guilty of vandalism: (1) Defaces with graffiti or other inscribed material. (2) Damages. (3) Destroys. Whenever a person violates this subdivision with respect to real property, vehicles, signs, fixtures, furnishings, or property belonging to any public entity, as defined by Section 811.2 of the Government Code , or the federal government, it shall be a permissive inference that the person neither owned the property nor had the permission of the owner to deface, damage, or destroy the property. (b)(1) If the amount of defacement, damage, or destruction is four hundred dollars ($400) or more, vandalism is punishable by imprisonment pursuant to subdivision (h) of Section 1170 or in a county jail not exceeding one year, or by a fine of not more than ten thousand dollars ($10,000), or if the amount of defacement, damage, or destruction is ten thousand dollars ($10,000) or more, by a fine of not more than fifty thousand dollars ($50,000), or by both that fine and imprisonment. (2)(A) If the amount of defacement, damage, or destruction is less than four hundred dollars ($400), vandalism is punishable by imprisonment in a county jail not exceeding one year, or by a fine of not more than one thousand dollars ($1,000), or by both that fine and imprisonment. (B) If the amount of defacement, damage, or destruction is less than four hundred dollars ($400), and the defendant has been previously convicted of vandalism or affixing graffiti or other inscribed material under Section 594 , 594.3 , 594.4 , 640.5 , 640.6 , or 640.7 , vandalism is punishable by imprisonment in a county jail for not more than one year, or by a fine of not more than five thousand dollars ($5,000), or by both that fine and imprisonment. (c) Upon conviction of any person under this section for acts of vandalism consisting of defacing property with graffiti or other inscribed materials, the court shall, when appropriate and feasible, in addition to any punishment imposed under subdivision (b), order the defendant to clean up, repair, or replace the damaged property himself or herself, or order the defendant, and his or her parents or guardians if the defendant is a minor, to keep the damaged property or another specified property in the community free of graffiti for up to one year.  Participation of a parent or guardian is not required under this subdivision if the court deems this participation to be detrimental to the defendant, or if the parent or guardian is a single parent who must care for young children.  If the court finds that graffiti cleanup is inappropriate, the court shall consider other types of community service, where feasible. (d) If a minor is personally unable to pay a fine levied for acts prohibited by this section, the parent of that minor shall be liable for payment of the fine.  A court may waive payment of the fine, or any part thereof, by the parent upon a finding of good cause. (e) As used in this section, the term “graffiti or other inscribed material” includes any unauthorized inscription, word, figure, mark, or design, that is written, marked, etched, scratched, drawn, or painted on real or personal property. (f) The court may order any person ordered to perform community service or graffiti removal pursuant to paragraph (1) of subdivision (c) to undergo counseling. (g) This section shall become operative on January 1, 2002. 1b. EXPERT WITNESS EXPLANATION 2009 California Evidence Code - Section 720-723 :: Article 1. Expert Witnesses Generally EVIDENCE CODE  SECTION 720-723  720. (a) A person is qualified to testify as an expert if he has special knowledge, skill, experience, training, or education sufficient to qualify him as an expert on the subject to which his testimony relates. Against the objection of a party, such special knowledge, skill, experience, training, or education must be shown before the witness may testify as an expert. (b) A witness' special knowledge, skill, experience, training, or education may be shown by any otherwise admissible evidence, including his own testimony. 721. (a) Subject to subdivision (b), a witness testifying as an expert may be cross-examined to the same extent as any other witness and, in addition, may be fully cross-examined as to (1) his or her qualifications, (2) the subject to which his or her expert testimony relates, and (3) the matter upon which his or her opinion is based and the reasons for his or her opinion. (b) If a witness testifying as an expert testifies in the form of an opinion, he or she may not be cross-examined in regard to the content or tenor of any scientific, technical, or professional text, treatise, journal, or similar publication unless any of the following occurs: (1) The witness referred to, considered, or relied upon such publication in arriving at or forming his or her opinion. (2) The publication has been admitted in evidence. (3) The publication has been established as a reliable authority by the testimony or admission of the witness or by other expert testimony or by judicial notice. If admitted, relevant portions of the publication may be read into evidence but may not be received as exhibits. 722. (a) The fact of the appointment of an expert witness by the court may be revealed to the trier of fact. (b) The compensation and expenses paid or to be paid to an expert witness by the party calling him is a proper subject of inquiry by any adverse party as relevant to the credibility of the witness and the weight of his testimony. 723. The court may, at any time before or during the trial of an action, limit the number of expert witnesses to be called by any party.

2. EDUCATIONAL CREDENTIALS  3. TECHNICAL EXPERIENCE 3a. RETIREMENT DOCUMENT FROM SHELL 3b. LETTER OF RECOMMENDATION FROM MR. TYLER CASE OWNER NEW LEAF BIOFUEL 3c. LETTER OF RECOMMENDATION FROM Ms. PORTIA SMITH PARTNER NEW LEAF BIOFUEL VIDEO EVIDENCES VIDEO 1 TAKEN MAY  5, 2020 4:46PM VIDEO FOOTAGE OF THE ACTUAL HOT WATER LEAK AND DEPTH MEASUREMENT OF THE ACTUAL LEAK TAKEN BY US CONTRARY TO THE NO LEAK SCENARIO MANIPULATED BY THE PLUMBER BY SETTING A MERE SLIGHT OPENING ON THE LINE TO THE WATER HEATER AND OPENING UP THE HOT WATER FAUCET ON THE KITCHEN SINK TO RELEASE PRESSURE. VIDEO 2 TAKEN  MAY 5,  2020 4:23PM VIDEO FOOTAGE OF THE ACTUAL HOT WATER LEAK THIS LEAK IS CONCEALED BY THE PLUMBER BY OPENING UP THE SINK HOT SIDE FAUCET AS EVIDENCED BY THE INCRIMINATING AUDIO OF THE GUY WHO WAS INSTRUCTED TO OPEN THE HOT SIDE FAUCET TO OBVIOUSLY TO RELEASE PRESSURE ON THE HOT WATER LINE....HEAR THE AUDIO ON VIDEO 5. VIDEO 3

TAKEN 5 MAY 2020

CHECKING IF THE MAIN VALVE TO THE WATER HEATER IS FULLY OPEN.. WE CHECK IT TOGETHER . HE TOLD ME ITS FULLY OPEN ...I PRETENDED TO AGREE WITH HIM BUT IN FACT

IT WAS NOT. IT IS JUST SLIGHTLY OPEN WHEN I CHECKED ON IT. I KNOW HOW IT FEEL VALVE OPENINGS BEING A PETROLEUM REFINERY OPERATIONS AND MAINTENANCE MAN FOR 25 YEARS.

VIDEO 4

TAKEN 5 MAY 2020

RATTLED PLUMBER AS HE SAW SOMETHING  THAT BOTHERED HIM SO MUCH. HE STOPPED DIGGING. HE FIXED SOMETHING IN THE HOT SIDE OF THE LINE AS HE INSTRUCTED HIS HELPER TO OPEN THE HOT SIDE KITCHEN SINK FAUCET THE PURPOSE OBVIOUSLY IS TO DEVOID THE HOT WATER LINE OF PRESSURE THEREBY HIDING THE LEAK TO US.

VIDEO 5

TAKEN 5 MAY 2020

INCRIMINATING SENTENCES

HOTSIDE....HOTSIDE...

THEN THE GUY WENT OUT TO THE KITCHEN SINK. MY DAUGHTER IS ASKING THE GUY WHO WENT TO THE SINK WHAT HE IS DOING. HE ANSWERED,  "HE TOLD ME TO OPEN THE FAUCET".

hear it again...HE TOLD ME TO OPEN THE FAUCET...

VIDEO 6

MAY 20,2020

HOT WATER LINE LEAK DETERIORATES

Video now May 20, 2020 after a couple of weeks,  the hot water line leak deteriorates and becomes more apparent and exposed clearly the leak that John, the plumber concealed from us. THE LEAK IS ON THE VERTICAL HOT WATER LINE IN THE SLAB AND NOT UNDER THE FOUNDATION AS HE INFORMED THE ADJUSTERS OF STATE FARM AND FIRST AMERICAN.

VIDEO 7

MAY 25, 2020

VIDEO TAKEN 4 DAYS  AFTER  REROUTE OF THE HOT WATER LINE ON THE PERIPHERALS OF THE COLD WATER LINE SHOWING 12% TO 17% DAMPNESS SIGN OF POSSIBLE IMPENDING LEAK IN THE COLD WATER LINES AND THE HOT AND COLD WATER LINES TO THE KITCHEN SINK DAMAGED BY THE DIGGING OPERATIONS CONDUCTED RECKLESSLY BY JOHN USING A FORCEFUL JACKHAMMER.

Notice the new hot water line copper pipe installed 4 days ago.

VIDEO 8

TAKEN MAY 5, 2020

AFTER  THE COMMOTION AND OPENING OF THE KITCHEN SINK HOT WATER FAUCET MY DAUGHTER TOOK THE VIDEO OF THE EXCAVATION. NOTICE THAT THE EXCAVATION COVERS ONLY SECTION 1 THEN THIS TIME JOHN STOPPED DIGGING SECTION 1 AND MOVED TO SECTION 2 FARTHER AWAY FROM SECTION 1

VIDEO 9

TAKEN MAY 5, 2020 

VIDEO SHOWING DELIBERATE AND INTENTIONAL HIDING THE LEAK FROM US THROUGH ORAL DENIAL OF THE EXISTENCE OF LEAK IN THE LINE. HE WAS ASKED WHETHER HE DID FIND THE LEAK ALREADY AND JOHN REPLIED A RESOUNDING "NO, NOT YET" THOUGH ACTUALLY HE FOUND IT. THIS IS AN UNEQUIVOCAL VIVID EXPRESSION OF HIS INTENTIONAL AND DELIBERATE DECEPTION, LYING AND CHEATING INTENTIONS.

VIDEO 10

TAKEN JUNE 21, 2020

SEQUEL TO VIDEO 7

VIDEO TAKEN 31 DAYS  AFTER  REROUTE OF THE HOT WATER LINE ON THE PERIPHERALS OF THE COLD WATER LINE SHOWING 20% TO 12% CONSISTENT DAMPNESS SIGN OF POSSIBLE IMPENDING LEAK IN THE COLD WATER LINES AND THE HOT AND COLD WATER LINES TO THE KITCHEN SINK DAMAGED BY THE DIGGING OPERATIONS CONDUCTED RECKLESSLY BY JOHN USING A FORCEFUL JACKHAMMER.

PICTURES EVIDENCES

PICTURE 1

TAKEN 7 MAY 2020

TOP VIEW OF THE EXCAVATED CONCRETE 

WITH AN AREA OF 1.5 SQUARE FEET

WITH A DEPTH OF 6 TO 4 INCHES ( NOT 10 INCHES) AS THE PLUMBER STATED

SECTIONS 1&2.

PICTURE 2

TAKEN 7 MAY 2020

SECTION 1 OF THE EXCAVATED CONCRETE 

TOP VIEW WITH DEPTH 6 TO 5 INCHES

FIRST THE PLUMBER DUG  SECTION 1 (PICTURE 2) TO A DEPTH OF 6 INCHES. THEN HE NOTICED TRACE OF LEAK IN THE HOT SIDE OF THE WATER LINE. HE INSTRUCTED HIS MAN TO OPEN THE HOT WATER FAUCET IN THE KITCHEN SINK. THE LEAK DISAPPEARED. THEN HE DUG AWAY FROM SECTION 1 TO THE  DIRECTION OF SECTION 2 (PICTURE 3)  

PICTURE 3

TAKEN 7 MAY 2020

SECTION 2 OF THE EXCAVATED CONCRETE 

TOP VIEW WITH DEPTH OF 5 TO 4 INCHES

HE STOPPED DIGGING ON SECTION 2 AFTER EXCAVATING LESS A SQUARE FOOT OF CONCRETE AND STATED HE IS STOPPING EXCAVATING  BECAUSE HE STRESS AN ASSUMPTION THAT THE LEAK IS UNDER THE FOUNDATION AND HE HAS DUG 10 INCHES DEPTH OF CONCRETE AND ITS THE MOST HE CAN DO. HE MADE A VIDEO OF HIS STATEMENTS AND THE EXCAVATION TO THE OTHER PERSON ON THE LINE, WHOM WE DO NOT KNOW WHO, DURING THAT TIME. LATER,  HOWEVER I LEARNED HE WAS TALKING TO THE ADJUSTER FOR THE SECONDARY DAMAGE WHEN THAT ADJUSTER CALLED INFORMING US THAT ON ACCOUNT OF THE VIDEO AND STATEMENTS OF THE PLUMBER SAYING THE LEAK IS UNDER THE FOUNDATION, HE IS DENYING OUR CLAIM FOR SECONDARY DAMAGE.  AND, THE FOLLOWING DAY WE RECEIVED A FORMAL DENIAL LETTER FROM THE HOME  INSURANCE.

STATE FARM INSURANCE DENIAL LETTER

PICTURE 1A

TAKEN MAY 5, 2020

EXCAVATION SECTION 1 ONLY TAKEN AFTER THE COMMOTION ON THE LEAK SHOWING UP ON THE HOT WATER LINE, THEN THEY STOPPED DIGGING SECTION 1 AND CONTINUED DIGGING AWAY FROM SECTION 1 TO SECTION 2 SHOWING DELIBERATE INTENT NOT TO FIX THE LEAK BUT TO JUST TO MAKE AN EXCAVATION USEFUL TO HIS INTENT TO FALSELY STATE THAT HE HAD EXCAVATED A LOT AND THAT HE WAS NOT ABLE TO SEE ANY LEAK AND THAT THE LEAK SHOULD BE FROM UNDER THE FOUNDATION  HE STRESSED, FOR THE BENEFIT OF STATE FARM INSURANCE.

PICTURE A

PICTURE B

NOTICE THE SOFT CONCRETE ON TOP OF THE LEAKING SPOT AN INDICATION THAT THE LEAKING LINE HAD UNDERWENT A PREVIOUS REPAIR AND COULD BE OPENED UP AGAIN NO NEED OF HELPERS AND THE JACKHAMMER AND BRINGING WITH HIM JUST A SMALLER ELECTRICAL  HAMMER AND MASONRY CHISEL WHICH WOULD NOT SHATTER THE FOUNDATION AND THE WATER LINES IN IT. NOTE THAT HE BROUGHT WITH HIM 2 HELPERS AND A MIGHTY JACKHAMMER  NOT REALLY TO REPAIR THE LEAKING HOT WATER LINE BUT DELIBERATELY HIDE IT FROM US AND TO INTENTIONALLY ACCOMPLISH HIS OBJECTIVE TO CREATE AN EXCAVATION TO PROVE THAT THERE IS "NO LEAK IN THE SLAB BUT A SUSPECTED LEAK UNDER THE FOUNDATION" GIVING HELP TO STATE FARM TO ESCAPE SECONDARY DAMAGE LIABILITY AND GETTING FROM FIRST AMERICAN A COSTLIER PIPE REROUTE THAN SIMPLE LEAK REPAIR.  WOULD YOU BELIEVE HIM IF HE SAYS , THE STATEMENTS AND THE VIDEO LIVE PRESENTATION PRODUCED BY HIM WERE FREE? JOHN DAMAGED OUR HOUSE STRUCTURALLY, AND HARMED US FINANCIALLY AND DEFRAUDED US AND FIRST AMERICAN AND ENRICHED STATE FARM INTENTIONALLY AT OUR EXPENSE.  HE MUST BE HOLD ACCOUNTABLE TO THIS WRONGDOING. OUR SOCIETY WOULD NOT BE SAFE WITH THIS MAN ROAMING AROUND DOING WRONGS SCOT FREE.

PICTURE C

COPPER PIPE, MAP OR PROFANE GAS CANISTER, TORCH AND OTHER SOLDERING MATERIALS COULD NOT BE SEEN ANYWHERE IN ALL THE VIDEOS  BUT JUST THE JACKHAMMER AN INDICATION THAT HE INTENDED JUST TO MAKE AN EXCAVATION  AND NOT TO REPAIR ANY LEAKING PART OF THE HOT WATER LINE. HE HAD CONDUCTED THE LEAK DETECTION ABOUT 4 DAYS AGO AND OBVIOUSLY KNEW WHERE THE LEAK IS AND HE SUPPOSED TO FIXING THE LEAK BUT HE CAME  WITHOUT THESE TOOLS AND MATERIALS, REVEALING OBVIOUSLY HIS INTENTION TO JUST MAKE AN EXCAVATION  WITHOUT ANY SHOWING OF LEAK AS EVIDENCE WHERE STATE FARM CAN RELY ON PURPOSELY TO DENY OUR INSURANCE CLAIM AGAINST STATE FARM.

PICTURE D

MAY 21, 2020 

HOT WATER LINE LEAK REPAIR REROUTE RECEIPT SIMPLE LEAK REPAIR WOULD NOT BE ADVISABLE ANYMORE AS PER THE NEW PLUMBER'S ASSESSMENT DUE TO THE DAMAGE IMPACTED BY THE JACKHAMMER TO THE HOT WATER LINES EMBEDDED IN THE SLAB COSTING US $1068.75 FROM OUR OWN POCKET.  NOTE THAT THE HOT WATER TO THE KITCHEN SINK NOT YET DONE YET.

PICTURE E

FOOD STAMP RECIPIENT EVIDENCE

PICTURE F

WEDNESDAY, MAY 6, 2020 MESSAGE FROM FIRST AMERICAN THAT ALL EXPRESS PLUMBING IS AUTHORIZED TO COMPLETE THE FOLLOWING REPAIRS. FAILURE, LEAKING WATER UNDERNEATH DINING ROOM HALLWAY WHICH WILL BE CORRECTED THIS WAY:  ACCESS PIPE ENCASED IN A CONCRETE SLAB AND REPAIR PIPE.  JUST A SIMPLE PIPE LEAK REPAIR AND JUST NEED A DELICATE MINUTE EXCAVATION NOT THE EXTENT WHERE THE CONCRETE SLAB, OUR PROPERTY WAS RUINED TO A POINT WHERE ALL THE PIPES ENCASED IN THE SLAB HAVE BEEN SUBJECTED TO TREMORS AND STRAINS AND STRESSES  AND IMPENDING LEAKS BY THE RECKLESS USE OF THE JACKHAMMER BY JOHN TITOUAH, WHICH IN OTHER WORDS, IS TANTAMOUNT TO VANDALISM.

PICTURE F1

ENLARGED WEDNESDAY, MAY 6, 2020 MESSAGE FROM FIRST AMERICAN HOME WARRANTY SAYING THE CORRECTION TO THE PROBLEM  IS TO ACCESS PIPE ENCASED IN CONCRETE SLAB AND REPAIR PIPE AND NOT TO EXCAVATE LEAKING PIPE UNDER THE FOUNDATION.  THOUGH I HAVE NOT SEEN  JOHN TITOUAH, THE PLUMBER,  REPORT ON WHERE THE LEAK IS,  BY VIRTUE OF THIS MESSAGE, IT CAN BE INFERRED WITH 100%ACCURACY THAT THE LEAK IS NOT UNDER THE FOUNDATION BUT IN THE PIPE ENCASED IN THE SLAB AS INFORMED AND INSTRUCTED AND ADVISED BY FIRST AMERICAN.