Claim Number 55-06c6-44x POSITIONS UNCHANGED BUT LIU CHANGED THEM HIMSELF dated 17aug20

AUGUST 17,  2020 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 POSITIONS UNCHANGED BUT LIU  CHANGED THEM HIMSELF  Dear Mr. Liu: PLEASE SEE, PAR. 5 DENIAL LETTER dated August 14, 2020  You wrote, " Your demand that the decision by State Farm to deny this claim be reversed is respectfully declined. Our position as communicated in our letters to you dated May 6, 2020, June 12, 2020, July 13, 2020, July 17, 2020 and July 31, 2020 are unchanged. This claim file remains closed. All conditions previously quoted still apply. " You wrote, specifically, " Our position as communicated in our letters to you dated May 6, 2020, June 12, 2020, July 13, 2020, July 17, 2020 and July 31, 2020 are unchanged.  " COMMENTS : Please be clear. State what position exactly you are referring to. It is confusing for me to understand what message you want to deliver.  What position are you writing that are unchanged. Write them down clearly and straight forward.  In fact, the record of our communications showed you had changed your position, see  your denial letters dated May 6, 2020  and June 12, 2020 in particular carried with it messages pertaining to written report by John Titouah submitted to you, but in denial letter dated July 31, 2020 you denied existence of Titouah's written report but only verbal conversation. That is why I am commenting please be clear and on what you are writing to avoid confusion. NOW PLEASE CHOOSE AMONG THE DENIAL LETTERS OF   May 6, 2020, June 12, 2020, July 13, 2020, July 17, 2020 and July 31, 2020 YOU WANT TO RE WRITE TO DELIVER YOUR MESSAGE CLEARLY REFLECTING CHANGES YOU WANTED TO PURSUE. Please acknowledge receipt of this e-mail and kindly inform me when I should expect a reply to this email. 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. Thank you very much. Yours faithfully, Antonio L. Buensuceso

Claim Number 55-06c6-44x CITE ISSUES AND REASONS WHY YOU AFFIRMED DENIAL OF CLAIM dated 17aug20

AUGUST 17,  2020 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 CITE ISSUES AND REASONS WHY YOU AFFIRMED DENIAL OF CLAIM Dear Mr. Liu: PLEASE SEE, PAR. 5 DENIAL LETTER dated August 14, 2020  You wrote, " Your demand that the decision by State Farm to deny this claim be reversed is respectfully declined. Our position as communicated in our letters to you dated May 6, 2020, June 12, 2020, July 13, 2020, July 17, 2020 and July 31, 2020 are unchanged. This claim file remains closed. All conditions previously quoted still apply. " You wrote, specifically, " Your demand that the decision by State Farm to deny this claim be reversed is respectfully declined.  " COMMENTS : It is not fair that you will just state " Your demand that the decision by State Farm to deny this claim be reversed is respectfully declined. " without showing issues which you have taken into consideration and proven that you have shown a great amount of effort to carefully and prudently study all of them. Please write down all the issues that you look into and write to me why those issues would not merit approval of my pleadings. So that I may have a chance to know what more you need to prove my cause. Please acknowledge receipt of this e-mail and kindly inform me when I should expect a reply to this email. 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. Thank you very much. Yours faithfully, Antonio L. Buensuceso

Claim Number 55-06c6-44x FIVE (5) UNDISPUTED FACTS PROVING STATE FARM AND LIU ARE PARTIES TO TITOUAH'S CRIMES dated 17aug20

AUGUST 17,  2020 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 FIVE (5) UNDISPUTED FACTS PROVING STATE FARM AND LIU ARE PARTIES TO TITOUAH'S CRIMES Dear Mr. Liu: PLEASE SEE, PAR. 5 DENIAL LETTER dated August 14, 2020  You wrote, " Your email contains allegations of misconduct by John Titouah. State Farm will not respond to your allegations against John Titouah. However, to the extent you allege State Farm is a party to a crime you allege was committed by John Titouah, State Farm denies that contention. " COMMENTS : Mere words of denials to the allegations of misconduct by State Farm and you are worthless without showing actions proving that State Farm and you are not party to his crime. TO WIT, AMONG OTHERS: STATE FARM AND YOU ARE MOST PROBABLY PARTY TO HIS CRIMES OF PRODUCING AND DISTRIBUTING A RIGGED FRAUDULENT VIDEO AND BY WAY OF VANDALISM, DIGGING A HUGE EXCESS EXCAVATION MORE THAN WHAT IS REQUIRED TO ACCESS PIPE WITHIN THE SLAB AND REPAIR PIPE, being you as: 1. THE MAIN BENEFICIARY OF THE RIGGED FRAUDULENT VIDEO PRESENTATION AND STATEMENTS  AS YOU USED AND RELIED ON THEM TO DENY OUR CLAIM. 2. DESPITE THE FACT THAT I HAVE REPORTED HIS CRIME TO CONCERNED POLICE AGENCIES AND THIS FACT HAVING BEEN PRESENTED TO YOU, I AM PERPLEXED WHY YOU HAVE  NOT SHOWN OR WRITTEN CONCRETE ACTIONS TO INVESTIGATE OR AT LEAST VERIFY FACTS RELEVANT TO THE ALLEGATIONS OF FRAUD BY TITOUAH OR WRITE ACTIONS TAKEN TO SEEK HELP FROM THE POLICE IN INVESTIGATING TITOUAH. 3. HAVING BEEN VISITED THE SITE OF HIS CRIME AND INVITED PURPOSELY TO TAKE MEASUREMENTS OF THE EXCAVATION, BUT YOU DID NOT TAKE MEASUREMENTS OR EVEN AT LEAST BRING WITH YOU A MEASURING TOOL AND WORSE, YOU STILL MAINTAIN YOUR POSITION OF 10, 8 TO 9 AND 8 INCHES DEPTH OF THE EXCAVATION IN YOUR DENIAL LETTERS, WHICH ARE FAR FROM THE ACTUAL DEPTH MEASUREMENT OF 4 TO 6 INCHES. 4. HAVING YOU STATED  THAT " It does not matter which plumber is called, who they worked for, and what they charge, the only way to confirm the Predominant cause of water losses is to contact and discuss the facts of the discharge directly with the plumber who discovered, located, and repaired the leak.",  You wrote, "what they charge, " MEANS THAT YOU IMPLICITLY ADMITTED THAT THE PLUMBER TITOUAH CHARGES FEES AND YOU PAID HIM FOR THE SERVICES HE HAD RENDERED FOR YOUR BENEFIT. IN OTHER WORDS, YOU HAVE  CREATED A BUSINESS PARTNERSHIP WITH TITOUAH WHERE YOU ARE HIS CLIENT FOR THE RIGGED VIDEO PRESENTATION HE PRODUCED.  DOUBTLESS, THAT TITOUAH AND YOU ARE PARTNERS IN THIS ENDEAVOR . AND, THEREFORE,  YOU CAN NOT DENY THAT STATE FARM AND YOU ARE PARTY TO THE CRIMES COMMITTED BY TITOUAH. 5.  HAVING YOU STATED  THAT " It does not matter which plumber is called, who they worked for, and what they charge, the only way to confirm the Predominant cause of water losses is to contact and discuss the facts of the discharge directly with the plumber who discovered, located, and repaired the leak." MEANS THAT ACCORDING TO WHAT YOU HAVE WRITTEN, " the only way to confirm the Predominant cause of water losses is to contact and discuss the facts of the discharge directly with the plumber who discovered, located, and repaired the leak." THEN IT FOLLOWS YOU NEED TO CONTACT A PLUMBER  WHO DISCOVERED, LOCATED  AND REPAIRED THE LEAK. BUT YOUR PROBLEM IS, THERE IS NO PLUMBER WHO DISCOVERED NOR LOCATED THE LEAK, BUT THE FACT IS IT IS US WHO DISCOVERED THE LEAK  NOT JOHN TITOUAH AND NEITHER HE REPAIRED THE LEAK. THEREFOR, THE RIGHT PERSON TO TALK TO IS NOT JOHN TITOUAH BUT US.  WHY NOT TALK TO US AND IGNORE TITOUAH?  IF NOT BOTH OF YOU ARE PARTNERS TO HIS CRIMES, HOW COME UP TO THIS TIME BOTH OF YOU ARE ONE TOGETHER IN HIS LIES?  SOURCE FOR NO. 4 and 5 ON PAR.4 June 12, 2020 denial letter You wrote,  "As far as State Farm's relationship with All Express Plumbing and John Titouah, all insurance carriers after a water loss has been immediately contacts and discusses causation and location of pipe breaks. It does not matter which plumber is called, who they worked for, and what they charge, the only way to confirm the Predominant cause of water losses is to contact and discuss the facts of the discharge directly with the plumber who discovered, located, and repaired the leak. In regards to the costs of a re-route, that would be up to the discretion of the Insured. 1. You wrote, "what they charge " meaning, in other words, plumber John charges fees and you paid him in return for his rigged live video presentation and fraudulent statements. How much did he charge you and the amount you paid him? 2. You wrote, "to contact and discuss the facts of the discharge directly with the plumber who discovered, located, and repaired the leak. " Why talk to John Titouah extensively and rely heavily on his statements? John Titouah, Yes he is a plumber. But he is not the one who discovered the leak. It is us. He is not the one who located the leak, It is us; and he is not the one who repaired the leak. Hence, John Titouah is not the right person to talk to but us. So talk to us not John.  AGAIN, JOHN DID NOT DISCOVER, LOCATE AND REPAIR the leak. Therefore,  he can not be called to testify on matters he did not witness or see. Please acknowledge receipt of this e-mail and kindly inform me when I should expect a reply to this email. 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. Thank you very much. Yours faithfully, Antonio L. Buensuceso

Claim Number 55-06c6-44x EMAILS WITH ALLEGATIONS OF MISCONDUCT BY TITOUAH BE IDENTIFIED AND CLASSIFIED AS EMAILS GORDON LIU WILL NOT RESPOND TO dated 17aug20

AUGUST 17,  2020 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 EMAILS WITH ALLEGATIONS OF MISCONDUCT BY TITOUAH BE IDENTIFIED AND CLASSIFIED AS EMAILS GORDON LIU WILL NOT RESPOND TO Dear Mr. Liu: PLEASE SEE, PAR. 5 DENIAL LETTER dated August 14, 2020  You wrote, " Your email contains allegations of misconduct by John Titouah. State Farm will not respond to your allegations against John Titouah. However, to the extent you allege State Farm is a party to a crime you allege was committed by John Titouah, State Farm denies that contention. " COMMENTS : Please indicate what particular email or emails you are referring to as to allegations of misconduct by John Titouah. I might be thinking and discussing  emails  which are entirely different of what you have in mind. So, kindly identify those emails and corresponding subject matters containing allegations of misconduct by John Titouah which as you wrote you will not respond to. Please write all of them down and send it to me and note that those emails contained John Titouah's misconduct which you unequivocally  declared, will not respond to. We must endeavor to make our positions clear to avoid confusion. Please acknowledge receipt of this e-mail and kindly inform me when I should expect a reply to this email. 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. Thank you very much. Yours faithfully, Antonio L. Buensuceso

Claim Number 55-06c6-44x 34 COUNTS BAD FAITH NIXES CLAIMS OF COMPLIANCE WITH THE IMPLIED COVENANT OF GOOD FAITH AND FAIR DEALING dated 17aug20

AUGUST 17,  2020 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 34 COUNTS BAD FAITH NIXES  CLAIMS OF COMPLIANCE WITH THE IMPLIED COVENANT OF GOOD FAITH AND FAIR DEALING Dear Mr. Liu: PLEASE SEE, PAR. 4 DENIAL LETTER dated August 14, 2020  You wrote, " Your email contains allegations of misconduct by me and State Farm. All such contentions are denied. We handle each claim on its own merits. State Farm and I have complied with the implied covenant of good faith and fair dealing in the investigation and handling of your claim.  " You wrote, specifically  " State Farm and I have complied with the implied covenant of good faith  and fair dealing in the investigation and handling of your claim." COMMENTS : Please RESPOND to each one of the THIRTY-FOUR (34) COUNTS OF AGGRAVATING BAD FAITH EVIDENCES AGAINST STATE FARM/GORDON LIU DATED JULY 31, 2020 and post your reasonable opposition on each one of the 34 counts of  AGGRAVATING BAD FAITH ALLEGATIONS and prove by exhibiting convincing evidence that STATE FARM AND YOU are not guilty of bad faith on each one of them. After which you may honestly state that STATE FARM AND YOU  had complied to the IMPLIED COVENANT OF GOOD FAITH AND FAIR DEALING.  Please acknowledge receipt of this e-mail and kindly inform me when I should expect a reply to this email. 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. Thank you very much. Yours faithfully, Antonio L. Buensuceso

Claim Number 55-06c6-44x IDENTIFY ALLEGATIONS OF MISCONDUCT BY STATE FARM AND YOU IN MY EMAILS dated 17aug20

AUGUST 17,  2020 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 IDENTIFY ALLEGATIONS OF MISCONDUCT BY STATE FARM AND YOU IN MY EMAILS Dear Mr. Liu: PLEASE SEE, PAR. 4 DENIAL LETTER dated August 14, 2020  You wrote, " Your email contains allegations of misconduct by me and State Farm. All such contentions are denied. We handle each claim on its own merits. State Farm and I have complied with the implied covenant of good faith and fair dealing in the investigation and handling of your claim.  " You wrote, specifically  " Your email contains allegations of misconduct by me and State Farm. All such contentions are denied." COMMENTS : Please name and identify allegations  of misconduct by STATE FARM AND YOU which you read contained in my emails. Then, deny each one of them substantiated with valid proofs and evidence why you are denying each one of them. Then give me a chance to contradict each one of them WITH  EXACT JUSTIFICATIONS  to prove that STATE FARM AND YOU are guilty of those allegations. Please acknowledge receipt of this e-mail and kindly inform me when I should expect a reply to this email. 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. Thank you very much. Yours faithfully, Antonio L. Buensuceso

Claim Number 55-06c6-44x LYING CONFIRMED ON PHOTO MEDIA SHEET ATTACHMENT BY GORDON LIU DATED 17AUG20

AUGUST 17,  2020 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 LYING CONFIRMED ON PHOTO MEDIA SHEET ATTACHMENT BY GORDON LIU Dear Mr. Liu: PLEASE SEE, PAR. 3 DENIAL LETTER dated August 14, 2020  You wrote, " If you did not receive the copy of the Claims Xperience photo media sheet which was enclosed with my July 31, 2020 correspondence, a second copy of those damaged photographs is attached." PAR. 3 July 31,2020 DENIAL LETTER You 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." COMMENTS : Please SEE the screenshot of your  response email dated July 31, 2020 below where there is only one document attachment on your response email dated July 31, 2020. And there is no evidence to show that you actually attached the media sheet photographs document with it.  It is not important whether you enclosed  or not copy of the media sheets photographs with the denial letter dated July 31, 2020 you think you sent through the postal mail. Besides I will let you know when your letter dated July 31, 2020 delivered through the postal mail comes. What is important is that I have proven you to be lying when you wrote the denial letter dated July 31, 2020 in the matter of attaching the media sheets photographs that you wrote attached but actually are not.  PAR. 3 of DENIAL LETTER dated August 14, 2020 is your implied admission that you did not attach the photo media sheet on the denial letter dated July 31, 2020. Please acknowledge receipt of this e-mail and kindly inform me when I should expect a reply to this email. 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. Thank you very much. Yours faithfully, Antonio L. Buensuceso