Claim Number 55-06c6-44x INAPPROPRIATE RESPONSE 68 DATED 25FEB21 10:48PM

FEBRUARY 25, 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  STATE FARM INAPPROPRIATE RESPONSE 68 DATED 25FEB21 12:19PM NOTES ON IMPROPRIETY : PERTAINING TO INAPPROPRIATE RESPONSE 68. NUMBER 1. MR. GUENIOT, MAY I MOST RESPECTFULLY REMIND YOU THAT YOU ARE AN EDUCATED MAN AND YOU ARE NOT DUMB, PLEASE PARDON ME FOR THE WORD BUT I AM FORCED TO WRITE IT IN ACCOUNT OF YOUR DELIBERATE AND INTENTIONAL IDIOCY AND MALEVOLENCE.  THE ASSISTANCE SOUGHT IS,  PLEASE PROVIDE ME 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 responses dated  February 11, 2021 and February 25, 2021. Without prejudice to the continuing violation doctrine which I have invoked, State Farm had a denial letter dated July 17, 2020 where it specifically mentioned the date of July 17, 2020 is the date when the one year suit statute of limitations shall begin, meaning that the one year limitation for suit is tolled again to the date of the July 17, 2020 denial letter. Kindly make your position clear consistent with the established facts. If you still insist that the one year limitation date shall start June 12, 2020 then this is intentional and deliberate manifestation of misrepresentation, an obvious display of bad faith. 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 INITIALLY 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 68 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 37/38/39/40/41/42/43/44/45/46/47/48/49/50/51/52/53/54/55/56/57/58/59/62/63/64/65/66/67 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: Claim Number 55-06c6-44x INAPPROPRIATE RESPONSE 67 DATED FEBRUARY 11, 2021 11:38PM NOTES ON IMPROPRIETY : PERTAINING TO INAPPROPRIATE RESPONSE 68 SHOWN ABOVE. THIS SHOWS: EVIDENCE OF THE 68TH 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 EIGHT (68) RECORDED INAPPROPRIATE RESPONSES AND/OR MISCONDUCTS TO SOW CONFUSION AND INTENTIONALLY AND DELIBERATELY DERAIL AND DELAY THE PROCEEDINGS. HOWEVER, AGAIN, HIS  INAPPROPRIATE RESPONSE 68,  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 68.  IN OTHER WORDS,  SIXTY EIGHT (68) 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

STATE FARM INAPPROPRIATE RESPONSE 68 DATED 25FEB21 12:19PM

INAPPROPRIATE RESPONSE 68 INAPPROPRIATE RESPONSE TO EMAIL:  STATE FARM INAPPROPRIATE RESPONSE 67 DATED FEBRUARY 11, 2021 09:03AM NOTES ON IMPROPRIETY : PERTAINING TO INAPPROPRIATE RESPONSE 68 NUMBER 1. MR. GUENIOT,  MAY I MOST RESPECTFULLY REMIND YOU THAT YOU ARE AN EDUCATED MAN AND YOU ARE NOT DUMB, PLEASE PARDON ME FOR THE WORD BUT I AM FORCED TO WRITE IT IN ACCOUNT OF YOUR DELIBERATE AND INTENTIONAL IDIOCY AND MALEVOLENCE.  THE ASSISTANCE SOUGHT IS,  PLEASE PROVIDE ME 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. TO WIT: FAILURE TO PROVIDE WRITTEN A CLEAR SUBSTANTIVE DENIAL DOCUMENTS CORRESPONDING TO THEM  ARE CLEAR VIOLATIONS  OF SECTION 2695.5.  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 DID NOT 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) FEEBLE MINDED OR FEW INSANE SENTENCES, REPEATEDLY ALL OVER AGAIN? WHAT YOU HAVE DONE BEST IS TO SOW MORE AND MORE CONFUSIONS TO DETER ME CONTINUING NEGOTIATIONS WITH YOU AND SUBJECT OUR CLAIM TO FRIVOLOUS DELAYS.  BUT I ASSURE YOU, I WILL CONTINUE GOOD FAITH NEGOTIATIONS WITH YOU THOUGH YOU ARE CONTINUALLY DISPLAYING OBVIOUS AND REPREHENSIBLE MANIFESTATIONS OF BAD FAITH AND/OR I WILL EXHAUST ALL ADMINISTRATIVE DISPUTE RESOLUTIONS AVAILABLE  BE IT WITHIN THE PREMISES OF STATE FARM, THROUGH MS. TIFFANY WYATT OR THROUGH THE MANAGERS ABOVE YOU OR THROUGH OUR INSURANCE AGENT, MR. EDDIE ATCHLEY OR THROUGH PUBLIC ADJUSTING SERVICES. I WOULD LIKE TO REITERATE THAT I WILL CONTINUE MY GOOD FAITH NEGOTIATIONS WITH YOU AND STATE FARM UNTIL I HAVE EXHAUSTED ALL ADMINISTRATIVE REMEDIES AVAILABLE. 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 INITIALLY 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. HIGHLIGHTS :  CONTINUING REITERATION OF SUBSTANTIVE DENIAL LETTERS ON VANDALISM FILED IN NOVEMBER 2020 AND SECONDARY DAMAGES CLAIM FILED IN JUNE 2020. 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 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 responses                   dated February 11, 2021 and February 25, 2021. Mr. Liu wrote July 17, 2020      and not June 12, 2020. Please read my supporting document  for date July 17,       2020  as the beginning of the one year statute of limitations : STATE FARM             RESPONSE DATED JULY 29, 2020 WITH ATTACHED AFFIRMED THIRD               DENIAL LETTER DATED JULY 17, 2020 . Without prejudice to the continuing         violations doctrine which I have invoked, as far as State Farm is concerned             the date July 17, 2020 shall prevail over June 12, 2020 because  July 17, 2020       is the date specifically mentioned in paragraph 3 of the July 17, 2020 denial             letter.  If you still insist it to be June 12, 2020, then this is deliberate and                   intentional misrepresentation, a manifestation of bad faith and futile efforts to           sow more confusions. 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 on 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.  NUMBER 2. DELIBERATE INTENTION TO SOW CONFUSION. IT IS AN IMPROPER RESPONSE FOR RESPONDING TO EMAILS WITH DIFFERENT SUBJECTS WHICH TEND TO CREATE MORE CONFUSIONS. DENIALS AND ASSERTIONS NEEDED TO BE  SUBSTANTIATED, OTHERWISE, CRIMINALS MERE  SAYING EMPTY WORDS OF DENIAL AND STATEMENTS  WOULD NEVER BE CONVICTED. CLEARER READING BELOW OF THE EMAIL SCREENSHOT ABOVE: Dear Mr. Buensuceso,   The email below has been received.   This claim file remains closed.  Our position as communicated in our letters and responsive emails are unchanged.  All conditions previously quoted still apply.    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 email contains 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

Claim Number 55-06c6-44x INAPPROPRIATE RESPONSE 67 DATED FEBRUARY 11, 2021 11:38PM

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 STATE FARM INAPPROPRIATE RESPONSE 67 DATED FEBRUARY 11, 2021 09:03AM 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: Claim Number 55-06c6-44x INAPPROPRIATE RESPONSE 66 DATED 27JAN21 9:08 PM 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