FEBUARY 11, 2021
LOUIS E. GUENIOT
TEAM MANAGER
GORDON LIU
CLAIM SPECIALIST
STATE FARM HOME INSURANCE
RE: Claim Number 55-06c6-44x
Policy Number 77-C3-B499-7
DATE OF LOSS: April 26, 2020
NOTES ON IMPROPRIETY : PERTAINING TO INAPPROPRIATE RESPONSE 67.
NUMBER 1.
MR. GUENIOT, THE ASSISTANCE SOUGHT IS, PLEASE PROVIDE A CONCISE SUBSTANTIVE DENIAL LETTER ON MY CLAIMS FOR SECONDARY DAMAGES FILED IN JUNE 2020 AND VANDALISM WHICH COVERAGE I DISCOVERED JUST IN NOVEMBER 4, 2020 WHEN YOU BELATEDLY FURNISHED ME WITH THE COPY OF THE POLICY BEYOND ON WHAT IS REQUIRED BY THE REGULATION.
WHY DO YOU NEED TO PROVIDE A CONCISE SUBSTANTIVE DENIAL LETTER?
1. Your denial letter must be accurate and not confusing. State Farm had an affirmed denial letter dated July 17, 2020. On paragraph 3 of this letter, Mr. Gordon Liu wrote the following:
"In your request that our correspondences be re-organized and re-written,
we respectfully respond that we will not. Please refer to May 6, 2020 correspondence and specifically the one year suit against us paragraph. The one year cited begins again as of the date of this letter."
Meaning, according to Mr. Liu, the one year suit begins again as of the date of that letter, July 17, 2020 and not June 12, 2020 as in your response dated February 11, 2021. Kindly make your position clear.
2. Again, your denial letter must be accurate and not confusing.
ON PAR.2 June 12, 2020 DENIAL LETTER, Mr. Liu wrote,
"As outlined in our May 6, 2020 declination letter, the predominant cause of the water damages was wear, tear, and deterioration to the forty one year old "hot" side copper water line located under the concrete foundation which resulted in a continuous and repeated seepage of water below the foundation, eventually migrated upwards and manifested itself on the date of the discovery to the interior of the home. My virtual inspection on May 5, 2020, the photographs of the excavating of the pipe, multiple discussions with All Express Plumbing, his written report and a detailed follow up conversation with the plumber, John Titouah on June 5, 2020 confirmed all the original facts of the loss."
"his written report "
This means on the denial letter dated June 12, 2020, Mr. Liu impressed upon us a copy of the written report of JOHN TITOUAH. BUT HOW COME MR. LIU IS DENYING THE EXISTENCE OF JOHN TITOUAH's REPORT ON PAR.3 JULY 31, 2020 DENIAL LETTER TO THE EFFECT THAT THE INFORMATION PROVIDED BY JOHN TITOUAH WAS PROVIDED VERBALLY AND NOT IN WRITTEN FORM.
PAR. 3 July 31, 2020 DENIAL LETTER Mr. Liu 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." Again, kindly clear the conflicting contrary position.
3. Please write a clear denial letter on my claim on vandalism which coverage I discovered just only on November 4, 2020 when you belatedly furnished me with a copy of the policy which I requested far beyond what is required by the regulation.
TO WIT:
FAILURE TO PROVIDE WRITTEN A CLEAR SUBSTANTIVE DENIAL DOCUMENTS CORRESPONDING TO THEM ARE CLEAR VIOLATIONS OF SECTION 2695.5.
Section 2695.5. Duties upon Receipt of Communications(b) Upon receiving any communication from a claimant, regarding a claim, that reasonably suggests that a response is expected, every licensee shall immediately, but in no event more than fifteen (15) calendar days after receipt of that communication, furnish the claimant with a complete response based on the facts as then known by the licensee. This subsection shall not apply to require communication with a claimant subsequent to receipt by the licensee of a notice of legal action by that claimant.
NUMBER 2.
DELIBERATE INTENTION TO SOW CONFUSION.
IT IS AN IMPROPER RESPONSE FOR RESPONDING TO AN EMAIL ASKING FOR A CLEAR AND CONCISE DENIAL LETTER LIKE "As I previously communicated to you on November 13, 2020, we have done our best to answer your questions and provide a reasonable explanation for the basis of the denial of the claim based on the policy language. " WHERE IN YOUR EMAIL IN NOVEMBER 13, 2020 YOU PROVIDE A REASONABLE EXPLANATION? YOU DID NOT EVEN MENTION OF MY DAMAGES CLAIM FROM VANDALISM COMMITTED BY YOUR INFORMANT PLUMBER TITOUAH?
NUMBER 3.
YOU ARE SAYING "we have done our best" WHAT EFFORTS HAVE YOU MADE TO EXPLAIN YOUR POSITION? WHAT YOU HAVE WRITTEN ME ARE JUST A TEMPLATE OF EMPTY AND UNSUBSTANTIATED FIVE (5), THREE (3) OR LESSER FEEBLE MINDED OR FEW INSANE SENTENCES, REPEATEDLY ALL OVER AGAIN. WHAT YOU HAVE DONE BEST IS TO SOW MORE AND MORE CONFUSIONS AND FRIVOLOUS DELAY TO DETER ME CONTINUING NEGOTIATIONS WITH YOU. BUT I ASSURE YOU, I WILL CONTINUE GOOD FAITH NEGOTIATIONS WITH YOU THOUGH YOU CONTINUALLY DISPLAY OBVIOUS AND REPREHENSIBLE MANIFESTATIONS OF BAD FAITH.
NUMBER 4.
MR. GUENIOT , PLEASE DO NOT DERAIL EFFORTS TO RESOLVE THIS CONFLICT TOWARD A HOLISTIC RESOLUTION. THIS EMAIL WHICH YOU ARE RESPONDING TO IS INTENDED FOR MR. EDDIE ATCHLEY AND NOT FOR YOU TO ANSWER. I FURNISHED YOU A COPY OF IT FOR THE SAKE OF COURTESY JUST TO LET YOU KNOW THAT I AM PRUDENTLY EXPLORING OPTIONS TO NEGOTIATE THESE INSURANCE CLAIMS BETWEEN RESPECTABLE AND HONORABLE MEN. STATE FARM INSURANCE COMPANY DESERVES MEN OF HIGH HONOR AND INTEGRITY IN THE EXACT OPPOSITE OF WHAT YOU ARE SHOWING. PLEASE LET MR. EDDIE ATCHLEY DO WHATEVER HE COULD TO HELP US OUT OF THIS PREDICAMENT.
INAPPROPRIATE RESPONSE 67
REPEATED MISCONDUCTS
FROM
INAPPROPRIATE RESPONSES
MULTIPLE MISCONDUCTS
1 TO 8 AND 9/10/11/12/13 AND 14
AND 15/16/17/18/19/20/21/22/23/24/25/26/27/28/29/30/31/32/33/34/35/36
AND 37/38/39/40/41/42/43/44/45/46/47/48/49/50/51/52/53/54/55/56/57/58/59/62/63/64/65/66
BEING NOT DISPUTED, OBJECTED AND HABITUALLY REPEATED WITH IMPUNITY. HENCE, PROVEN TO BE INTENTIONAL, DELIBERATE, MALICIOUS, WILLFUL, WANTON, OPPRESSIVE AND OUTRAGEOUS
AND BEYOND REASONABLE DOUBT
Dear Messrs Gueniot and Liu:
PLEASE SEE,
As Mr. Gueniot responded to email as shown next:
NOTES ON IMPROPRIETY : PERTAINING TO INAPPROPRIATE RESPONSE 67 SHOWN ABOVE.
THIS SHOWS:
EVIDENCE OF THE 67TH RECORDED MISCONDUCT, PROOF BEYOND REASONABLE DOUBT OF,
REPEATED HABITUALLY, INTENTIONALLY, DELIBERATELY OF OUTRAGEOUS MISCONDUCTS RESPONDING TO EMAILS SUBJECT OUTSIDE OF THE SUBJECT UNDER DISCUSSION AND/OR RESPONDING TO EMAILS NOT ADDRESSED TO HIM TO RESPOND AND/OR RESPONDING TO SEVERAL EMAILS ONCE LEAVING OTHER EMAILS NOT RESPONDED. AND VIOLATION OF DUTIES UPON RECEIPT OF COMMUNICATION SECTION 2695.
HE HAD SHOWN A TOTAL OF SIXTY SEVEN (67) RECORDED INAPPROPRIATE RESPONSES AND/OR MISCONDUCTS TO SOW CONFUSION AND INTENTIONALLY AND DELIBERATELY DERAIL AND DELAY THE PROCEEDINGS. HOWEVER, AGAIN, HIS INAPPROPRIATE
RESPONSE 67, THOUGH WORTHLESS SIMPLY BECAUSE THE CONTENTS ARE NOT RELATED TO THE QUESTION POSTED FOR HIM TO ADDRESS AND/OR OUTSIDE OF THE SUBJECT MATTER OF THE DISCUSSION AND/OR PROFESSIONALLY DISRESPECTFUL RESPONSE BUT BECOME A BIG HELP TO BOLSTER MANIFESTATION OF BAD FAITH CLAIM AGAINST STATE FARM.
YOUR ACTIONS, MR. GUENIOT TEND TO SHOW
THAT YOU MIGHT BE THE REAL MASTERMIND OF
TITOUAH'S CRIMES.
SO, MR. GUENIOT, AGAIN, MAY I REQUEST FOR YOUR KIND UNDERSTANDING. WE NEED TO HAVE OUR NEGOTIATION ORGANIZED AND RECORDS CLEAR, SO THAT WE MAY AVOID CONFUSION. OBVIOUSLY, IT APPEARS THAT YOU WANTED MUCH EAGERLY TO CLOSE THE NEGOTIATION AND THE INVESTIGATION PROCESS. HOWEVER, YOUR EFFORTS ARE IN VAIN AS I SEE YOUR INAPPROPRIATE RESPONSES NOW ARE WANING TO ONLY FEW OR FIVE (5) OR THREE (3) WEAK, OR TWO (2) SENILE FEEBLE AND DESPICABLE PARAGRAPHS AND THUS, SIMPLY THIS FACT LEAD ME TO THINK YOU REALLY JUST WANTED TO AVOID QUESTIONS, WHICH ANSWERS OR NO ANSWER FROM YOU TEND TO SPILL THE BEANS OF MOST PROBABLY TITOUAH AND YOUR CRIMES IN PARTNERSHIP WITH HIM SIMPLY BY READING THE QUERIES SPECIALLY CRAFTED FOR YOU, WITH OR WITHOUT YOUR ANSWERS.
Please acknowledge receipt of this e-mail. THIS EMAIL RESPONSE IS INTENDED FOR YOUR COLLECTION OF NEW INFORMATION ON INAPPROPRIATE RESPONSES WHICH TO MY TALLY RIGHT NOW ROSE TO 67. IN OTHER WORDS, SIXTY SEVEN (67) COUNTS OF STATE FARM RECORDED MISCONDUCTS. THOSE UNRECORDED MISCONDUCTS, I AM STILL COLLECTING THEM AND I PROMISE I WILL ADD THEM TO THE LIST WHICH INFORMATION YOU MAY STILL WANTED TO KNOW.
MOREOVER, IF YOU THINK YOU CAN TAKE REFUGE ON STATUTE OF LIMITATIONS AS A LEGAL DEFENSE TO DISCOURAGE ME IN PURSUING GOOD FAITH NEGOTIATIONS WITH YOU, MAY I MOST RESPECTFULLY INFORM YOU THAT IN ACCOUNT OF YOUR UNABATED CONTINUING VIOLATION IN MULTIPLE WRONGFUL ACTS, FAILURES TO ACT, OR DECISIONS SUCH THAT THE LIMITATIONS PERIOD BEGINS TO RUN ON THIS COLLECTED MALFEASANCE ONLY WHEN THE DEFENDANT, YOU MR. GUENIOT, CEASES YOUR IMPROPER CONDUCT. SINCE YOU HAVE NOT STOPPED YOUR IMPROPER CONDUCT; HENCE, THE ONE YEAR LIMITATION PERIOD TO FILE SUIT AGAINST STATE FARM HAS NOT BEEN STARTED YET.
PLEASE RESTRICT ISSUES WITHIN THE CONTEXT OF THE SUBJECT MATTER TO AVOID INAPPROPRIATENESS AND CONFUSION.
PLEASE NOTE THAT WRITING A LOUSY REPLY TAKEN BASED FROM A TEMPLATE JUST A FEW MINUTES OR HOURS OR FOURTEEN (14) DAYS TO DEVIATE ATTENTION FROM WHAT YOU ARE PROVEN YOU ARE HABITUALLY DOING. SO IT WON'T MATTER ANYMORE, WHETHER IT TOOK YOU A FEW MINUTES OR HOURS OR FOURTEEN (14) DAYS BECAUSE IT DID NOT ERASE NOR BLEMISH THE ESTABLISHED FACT THAT THE MAY 6, 2020 DENIAL LETTER WAS RELAYED AND SENT TO US IN A FEW MINUTES IS ABSOLUTELY PART OF YOUR PLAN CONCEIVED AND PREPARED MANY DAYS IN ADVANCE.
Thank you very much.
Yours faithfully,
Antonio L. Buensuceso
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