Claim Number 55-06c6-44x VANDALISM BY TITOUH DATED 17NOV20 7:37AM

NOVEMBER 17, 2020 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 DISCUSSION VANDALISM BY TITOUAH Dear Messrs Gueniot and Liu: SINCE YOU ARE UNABLE TO EXPLAIN THEN FOR THE PURPOSE OF HAVING HOLISTIC DISCUSSION/NEGOTIATION INVOLVING VANDALISM BY TITOUAH IN REFERENCE TO YOUR STATEMENT: "John Titouah excavating a portion of the concrete to search for the leak in a supply line to "fix it" is not an accident, and is not vandalism to personal property.....", May most humbly present to you, the UNOBJECTED AND UNDISPUTED ESTABLISHED FACTS relevant to the issue. 1. DATE OF LOSS  :  SUNDAY APRIL 26, 2020 2. DATE OF REPORT OF THE INCIDENT : MONDAY MORNING APRIL 27,2020 3. DATE JOHN TITOUAH CAME FOR LEAK DETECTION : APRIL 30, 2020     USING SOPHISTICATED ACCURATE INSTRUMENT. THUS, HE KNEW WHERE          THE PIPE BREAK IS.      4. WE REQUESTED FOR WRITTEN REPORT OF LEAK, PLUMBER TITOUAH                REFUSED. 5. TITOUAH REFUSED TO GIVE US, HIS CUSTOMER BUT      HE GAVE YOU THE WRITTEN REPORT, PERPLEXING.      EVIDENCE IS THE FOLLOWING: ON PAR.2 June 12, 2020 DENIAL LETTER You 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." 6. ANYWAYS, WE (WITH TITOUAH) DISCUSS 2 OPTIONS TO REPAIR THE LEAK:     OPTION 1 ACCESS PIPE AND REPAIR PIPE COSTING $700 COVERED BY                                  INSURANCE     OPTION 2 HIS SUGGESTION DO A PIPE RE-ROUTE                       BUT PAY HIM EXTRA $3600 FROM OUR POCKETS                       AND HE WILL GET PAYMENT FOR INSURANCE COVERAGE                       WE AGREED TO DO OPTION 1 BECAUSE $700 CAN BE WELL                                    TAKEN CARED OF BY THE INSURANCE.        NOTE :  IF JOHN DID NOT WANT TO FIX THE LEAK HE SHOULD                       HAD DECLINED DOING THE WORK SO THAT WE COULD                       HAD THE CHANCE LOOK FOR A PLUMBER WHO COULD DO                       THE FIXING OF THE LEAKING HOT WATER LINE FOR US. 7. TITOUAH CAME MAY 5, 2020 ABOUT 3PM WITH TWO HELPERS                      AND TOOK OUT THE SERVICE VAN A MIGHTY JACKHAMMER                                  ONLY.  NO BUTANE GAS CANISTER OR SOLDERING TORCH OR                              COPPER PIPES OR CONNECTORS OR SOLDERING GADGETS.                     THIS SEEMS TO BE A CLEAR SHOWING OF HIS INTENTION                     NOT TO FIX THE LEAK BUT TO EXCAVATE THE CONCRETE SLAB,                     BECAUSE IF HIS INTENTION IS TO FIX THE LEAKING PIPE, HE                                  COULD DO IT BY HIMSELF BRINGING WITH HIM SIMPLE                                            ELECTRICAL  MASONRY HAMMER AND CHISEL TOOLS.                     THIS SOMEHOW RAISED A RED FLAG TO US. HE MIGHT IN FOR                              SOMETHING ELSE. HOWEVER, WE RELIED HEAVILY ON HIS                                    ASSURANCE THAT HE WORKS FOR HOMEOWNERS AND NOT                                  FOR INSURANCE COMPANIES. HE FOUND THE LEAK AND HIDE IT.                     HE JUST DID MAKE AN EXCAVATION AND REPORTED TO YOU                                (GORDON) THROUGH LIVE VIDEO PRESENTATION THAT HE DID                              NOT FIND ANY LEAK  AND PRESUMED TO THE LEAK TO BE UNDER                        THE FOUNDATION. 8. YOU RELIED TO HIS STATEMENTS AND VIDEO PRESENTATIONS AND                      USED THEM TO DENY OUR CLAIM AS YOU RELAYED THAT                                      MESSAGE TO US ON MAY 5, 2020 AFTER TITOUAH LEFT. 9. AFTER DISCUSSING THE DENIAL MESSAGE WITH YOU (GORDON)                      WE CHECKED AND OPEN UP THE HOT WATER LINE AND                       NOTICED BUBBLES COMING OUT OF THE HOT WATER PIPE                      NOW EXPOSED AS THE CONCRETE CLOSED TO IT HAD BEEN                                 EXCAVATED. WE DISCOVERED THE PIPE BREAK WHICH TITOUAH                      CONCEALED FROM US AND NOT UNDER THE FOUNDATION. 10. HE DID NOT REPAIR THE PIPE BREAK, INSTEAD HE HIDE IT FROM US THEN                     CREATED AN EXCAVATION THROUGH VANDALISM WHICH HE USED                       TO HAVE A LIVE VIDEO PRESENTATION TO YOU (GORDON)                                     SHOWING THAT HE HAD EXCAVATED SO MUCH BUT HE DID NOT                           FIND ANY LEAK FOR YOUR BENEFIT, CONSEQUENTLY GIVING YOU                       THE REASON TO DENY OUR CLAIM.  11. ON MAY 6, 2020 WE RECEIVED A MESSAGE FROM FIRST AMERICAN THAT           TITOUAH HAS BEEN AUTHORIZED TO ACCESS PIPE ENCASED IN THE                   CONCRETE SLAB AND REPAIR PIPE AND NOT PIPE UNDER THE                             FOUNDATION. CLEARER READING BELOW OF THE SCREENSHOT MESSAGE ABOVE: Wednesday, May 6, 2020 @ 4:11PM Ms. Brual, All Express Plumbing has been authorized to complete the following repairs. Failure: Leaking water underneath dining room hallway. Correction: Access pipe encased in concrete slab and repair pipe. Have they contacted you to schedule an appointment to complete repairs, or has it already been completed? Please reach out to First American if you need any additional assistance. Thank you. 12. ON MAY 20, 2020 THE LEAK DETERIORATED AND BECAME MORE APPARENT. SCREENSHOT FROM VIDEO 6 TAKEN MAY 20, 2020 THE PIPE BREAK HAD DETERIORATED AFTER TWO WEEKS WHICH TITOUAH CONCEALED FROM US. 13. MAY I HUMBLY AND MOST RESPECTFULLY PRESENT TO YOU AGAIN IN MULTIPLE TIMES THE PIPE BREAK WHICH WE DISCOVERED AND DOCUMENTED AS EARLY AS JUNE 2020 AND COLLABORATED TWICE BY FIRST AMERICAN, FIRST ON MAY 6, 2020 SHOWN IN IYEM 10 AND ON, OCTOBER 24, 2020,  IS ON THE PIPE ENCASED IN THE CONCRETE SLAB AND NOT A PIPE BREAK UNDER THE FOUNDATION AND THEREFORE CLEARLY COVERED BY OUR POLICY: CLEARER READING BELOW OF THE SCREENSHOT MESSAGE ABOVE: Saturday, Oct 24, 2020 @ 10:24AM Good Morning, Thank you for reaching out to us in regards to this claim. I apologize for the delay in responding to your message. I have reviewed your claim on your pipe encased in concrete and show that the cash option check was mailed on 6/4/2020 and if the contractor did any damage to your property I would contact them directly to discuss the matter. If you need further assistance, please feel free to reply to this message. Thank you for choosing First American Home Warranty and enjoy the rest of your day.  14. AS CLEARLY ESTABLISHED THE PIPE BREAK IS ON THE VERTICAL HOT                WATER LINE AS SHOWN IN ITEM 11,12 AND 13, IT FOLLOWS THAT THE       EXCAVATION PICTURE 1A IS A NECESSARY PART OF THE WORK AND THIS          IS WHAT YOU ARE REFERRING TO AS  "NOT VANDALISM". 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. 15.  HOWEVER, TITOUAH EXCAVATING FARTHER AWAY FROM THE LEAKING               PIPE WHICH WAS NOT PART OF THE WORK HE WAS AUTHORIZED TO DO IS         WHAT I AM REFERRING TO AS VANDALISM AS SHOWN IN PICTURE A. PICTURE A 16. THEREFORE THE EXCAVATION NEXT IS A COMBINATION OF THE WORK HE IS SUPPOSED TO DO AND VANDALISM, WORK THAT HE IS FORBIDDEN TO DO. 17.  TO MAKE MY EXPLANATION CLEARER , MAY YOU PLEASE NOTICE THE YELLOW CUTOUT AND BLACK CUTOUT BOARDS. THE YELLOW CUTOUT REPRESENTS THE WORK WHICH IS INTENTIONAL AND NECESSARY TO FIX THE LEAK AND THE BLACK CUTOUT WHICH IS INTENTIONAL BUT UNNECESSARY TO FIX THE LEAK, IN OTHER WORD, VANDALISM. 18 . "John Titouah excavating a portion of the concrete to search for the leak in a supply line to "fix it" is not an accident, and is not vandalism to personal property.....", THIS YELLOW  CUTOUT BOARD   REPRESENTS YOUR STATEMENT. 19 . "John Titouah excavating a portion of the concrete to search for the leak in a supply line to "fix it" is not an accident, and is not vandalism to personal property.....", IN THIS BLACK  CUTOUT BOARD  YOUR STATEMENT IS NO LONGER TENABLE BECAUSE HE IS NO LONGER SEARCHING FOR LEAK. HE IS ACTUALLY MOVING AWAY FROM IT AND MAKING UNNECESSARY DESTRUCTIVE UNWANTED WORK TERMED AS VANDALISM. PLEASE REMEMBER TITOUAH ALREADY HAD THE PRECISE INFORMATION ON WHERE THE LEAK REFLECTIVE OF THE LOCATION WHERE WE DISCOVERED IT BECAUSE OF HIS SOPHISTICATED LEAK DETECTION INSTRUMENT HAD DEFINITELY REVEALED THIS INFORMATION TO HIM. 20. THIS BLACK CUTOUT        BOARD IS VANDALISM         AND IS INTENTIONAL. 20 AS A RESULT OF THE STRENUOUS IMPACT OF THE JACKHAMMER ON WHAT TITOUAH DID,  CONSTANT DAMPNESS IS NOTICEABLE ON THE SPOT WHERE THE OTHER WATER PIPES ARE ENCASED THOUGH THE HOT WATER PIPE WHICH IS LEAKING HAD ALREADY BEEN REROUTED. WE DO NOT KNOW WHICH ONES ARE CONTRIBUTING TO THAT DAMPNESS AND WHERE EXACTLY IT IS COMING FROM, SO, WE NEED TO REPIPE OTHER LINES WHICH MIGHT HAVE BEEN AFFECTED BY IT. 21.  SHOULD YOU STILL WANTED TO DENY THIS CLAIM ON DAMAGES CAUSED BY VANDALISM BY TITOUAH, THEN PLEASE WRITE A CLEAR DENIAL OF THIS CLAIM, MEANING A DENIAL LETTER WHICH IS SUFFICIENT IN FORM AND SUBSTANCE. Please acknowledge receipt of this e-mail and reply responsively.  PLEASE RESTRICT ISSUES WITHIN THE CONTEXT OF THE SUBJECT MATTER TO AVOID INAPPROPRIATENESS AND CONFUSION. Please be reminded that your DENIAL LETTER DATED MAY 6, 2020 was prepared, relayed to us, sent and read by us in just a few minutes though eventually proven to be maliciously defective. Thank you very much. Yours faithfully, Antonio L. Buensuceso

Claim Number 55-06c6-44x VANDALISM BY TITOUAH DATED 14NOV20 12:27PM

NOVEMBER 14, 2020 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 DISCUSSION VANDALISM BY TITOUAH Dear Messrs Gueniot and Liu: PLEASE SEE, As Mr. Gueniot responded to email as shown next: STATE FARM RESPONSE ON WATER DAMAGES (VANDALISM) DATED 13NOV20 7:42AM (TAKEN FROM INAPPROPRIATE RESPONSE 53. EXCAVATING A PORTION OF THE CONCRETE TO SEARCH FOR THE LEAK IN A SUPPLY LINE TO "FIX IT" IS NOT AN ACCIDENT......... ON PARAGRAPH 2, MR. GUENIOT  WROTE ,  We previously addressed your allegations of misconduct by John Titouah as referenced in your May 29, 2020 email in our June 12, 2020 and July 13, 2020 letters, along with our responsive emails.  Our May 6, 2020 correspondence stated that we insure for accidental direct physical loss to the property described in Coverage A.  The retaining of a plumber to “fix a leak” that results in the plumber, John Titiouah, excavating a portion of the concrete to search for the leak in a supply line to “fix it” is not an accident, and it is not vandalism to personal property as defined in the policy section included in your November 7, 2020 email.   SPECIFICALLY: The retaining of a plumber to “fix a leak” that results in the plumber, John Titiouah, excavating a portion of the concrete to search for the leak in a supply line to “fix it” is not an accident, and it is not vandalism to personal property as defined in the policy section included in your November 7, 2020 email.  I AM SORRY, I AM CONFUSED. KINDLY EXPLAIN WHAT  DO MEAN PRECISELY WITH YOUR STATEMENT :  "John Titiouah, excavating a portion of the concrete to search for the leak in a supply line to “fix it” is not an accident, and it is not vandalism to personal property....." I WILL REWRITE THE STATEMENT HERE FOR CLARITY.  "John Titouah excavating a portion of the concrete to search for the leak in a supply line to "fix it" is not an accident, and is not vandalism to personal property.....", Please acknowledge receipt of this e-mail and reply responsively.  PLEASE RESTRICT ISSUES WITHIN THE CONTEXT OF THE SUBJECT MATTER TO AVOID INAPPROPRIATENESS AND CONFUSION. Please be reminded that your DENIAL LETTER DATED MAY 6, 2020 was prepared, relayed to us, sent and read by us in just a few minutes though eventually proven to be maliciously defective. Thank you very much. Yours faithfully, Antonio L. Buensuceso

STATE FARM RESPONSE ON WATER DAMAGES (VANDALISM) DATED 13NOV20 7:42AM

STATE FARM RESPONSE  DATED 13NOV20 7:42AM EXCAVATING A PORTION OF THE CONCRETE TO SEARCH FOR THE LEAK IN A SUPPLY LINE TO "FIX IT" IS NOT AN ACCIDENT......... RESPONSE TO EMAIL: Claim Number 55-06c6-44x WATER DAMAGES BASIS OF DENIAL DATED 8NOV20 7:57AM WATER DAMAGES BASIS OF DENIAL. PLEASE EXPLAIN IN PLAIN STATEMENTS THAT WE COULD UNDERSTAND THE BASIS OF THE WATER DAMAGES DENIAL AND SHOW WHERE IN PAGES 1 TO 45 OF THE POLICY BOOKLET IT IS WRITTEN. CLEARER READING BELOW OF THE EMAIL SCREENSHOT ABOVE: Dear Mr. Buensuceso,   I’m writing to acknowledge receipt of the email below along with other emails from you since my last response to you on November 4, 2020.   We previously addressed your allegations of misconduct by John Titouah as referenced in your May 29, 2020 email in our June 12, 2020 and July 13, 2020 letters, along with our responsive emails.  Our May 6, 2020 correspondence stated that we insure for accidental direct physical loss to the property described in Coverage A.  The retaining of a plumber to “fix a leak” that results in the plumber, John Titiouah, excavating a portion of the concrete to search for the leak in a supply line to “fix it” is not an accident, and it is not vandalism to personal property as defined in the policy section included in your November 7, 2020 email.     This claim file remains closed.  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.  Our position as communicated in our letters dated May 6, 2020, June 12, 2020, July 13, 2020, July 17, 2020, July 31, 2020 and responsive emails are unchanged.  The May 6, 2020 letter included the applicable policy language.  All conditions previously quoted still apply.    We are required by California Insurance Regulations, Section 2695.7(b)(3), to advise you that if you believe this claim, or any part of this claim, has been wrongfully denied or rejected, you may have the matter reviewed by the California Department of Insurance, Claims Service Bureau, 300 South Spring Street, Los Angeles, California 90013, telephone 800 927 4357.   The one year “Suit Against Us” time period referred to in the May 6, 2020 letter includes the time period from the date of loss (April 26, 2020) to the date the claim was reported to State Farm (April 29, 2020).  The one year time period was tolled during our investigation of this claim (April 29, 2020) to the date the claim was initially denied (May 6, 2020).  The one year time period was tolled upon receipt of Antonio Buensuceso Jr.’s email dated May 29, 2020 for additional investigation until the date the denial of the claim was confirm in our June 12, 2020 letter.  That one year time period continues to run as of the date of our June 12, 2020 letter.     Your emails contain allegations of misconduct. All such contentions are denied. You should not interpret our silence as any agreement with you, or any waiver of our rights under the policy or law.  We reserve all rights under the policy and the law.    Sincerely,   Louis       Louis E Gueniot III Claim Team Manager State Farm General Insurance Company NOTE: ON PARAGRAPH 2, MR. GUENIOT  WROTE ,  We previously addressed your allegations of misconduct by John Titouah as referenced in your May 29, 2020 email in our June 12, 2020 and July 13, 2020 letters, along with our responsive emails.  Our May 6, 2020 correspondence stated that we insure for accidental direct physical loss to the property described in Coverage A.  The retaining of a plumber to “fix a leak” that results in the plumber, John Titiouah, excavating a portion of the concrete to search for the leak in a supply line to “fix it” is not an accident, and it is not vandalism to personal property as defined in the policy section included in your November 7, 2020 email.   SPECIFICALLY: The retaining of a plumber to “fix a leak” that results in the plumber, John Titiouah, excavating a portion of the concrete to search for the leak in a supply line to “fix it” is not an accident, and it is not vandalism to personal property as defined in the policy section included in your November 7, 2020 email.  I AM SORRY, I AM CONFUSED. KINDLY EXPLAIN WHAT  DO MEAN PRECISELY WITH YOUR STATEMENT :  "John Titiouah, excavating a portion of the concrete to search for the leak in a supply line to “fix it” is not an accident, and it is not vandalism to personal property....." I WILL REWRITE THE STATEMENT HERE  FOR CLARITY.  "John Titouah excavating a portion of the concrete to search for the leak in a supply line to "fixit"is not an accident, and is not vandalism to personal property.....",