For the sake of expediency, attached are responses to Requests for Admissions, Set Two, and Declaration of Linda Ayres. Proof of service included, and co-defense counsel will be served via my regular email address. It’s further burden for me, but since you complain either way I handle it, we’ll just leave it this way, so that other counsel will not be confused and respond at this address, which I monitor infrequently, for known reasons and purposes.
Counsel is also referred to email thread concluding October 18, 2022 5:36 am where in counsel states:
“Ms Ayres, I do not know what you mean by “volatile conditions”
Date of approved claim loss: 2/2/2019 – THE WIND PERIL/ROOF LOSS CLAIM WAS NOT DENIED. STATE FARM AND IT’S VENDORS AND ADJUSTERS CAUSED THE REST OF DAMAGES, AND COVERED IT UP VIA AEG ILLIGITIMATE ENVIORNMENTAL REPORTS AND EXTREME LAWFARE AND DISABILITY AND AGE AND GENDER DISCRIMINATION OF THE VICTIMIZED SELF-REPRESENTED PLAINTIFF.
As I believe it was Contractor Connection stated, discovery is unlikely to be completed before July 2023. I reserve the right to amend responses to attached admissions as new information is forthcoming.
Recent discovery that AEG parent company, McLarens company, is indeed an insurance company further supports the allegations related to the “litigation support” for which AEG was obviously retained by State Farm, with discussion with or agreement by Plaintiff/Policyholder,
Contractor Connection and Paul Davis Restoration web sites purport to be litigation support and/or the “eyes and ears of the insurance industry” and they also warn about the use of unscrupulous vendors who will take advantage of policy holders experiencing major losses. They also warn about the dangers of mis-handling of water damage and the threats that result in as few as 24 hours.
My house had no roof for over 40 days and there were multiple storms through the entire month of February 2019. That your client’s report of March 2019 and August 2019 showed no mold contamination, and some ‘unacceptable’ toxic mold species reported respectively, March and August, show either extreme incompetence or fraud. Because AEG and State Farm failed and refuse to produce documents of their communications and agreements, wildly alleging attorney client privilege even with ServPro, is highly suspicious and seems to point further to allegations of racketeering, as better outline in specific responses.
AEG has continued to act in that capacity since the first illegitimate “mold clearance report”,of March 2019 thrrough which is the proximate cause of the catastrophic damages and toxic exposure.
In answering these questions, I was reminded that original expectations were that loss of use would not be more than a few weeks.
Because of the “mold clearance report” in which State Farm Arizona adjusters and AEG parties apparently colluded and conspired in apparent efforts to cover up the negligence (gross or criminal) of the initials parties sent to the site, losses became catastrophic and life threatening.
If the new State Farm lawyers will take a look at the policy, they will see that the WIND PERIL AND ROOF LOSS were not denied claims, and that the unlawfully assigned vendors, coordinated by first adjuster, Randy Brewer, with allegedly over 30 years experience, with deceptions and cover up that caused the damages, with AEG being the most culpable culprit due to the illegitimate March “mold clearance report” — State Farm Counsel might see the value in settling the claim properly, then moving forward with subrogation, which Randy Brewer suggested would be a consequence when he finally authorized replacement of the assigned vendors. At no time was “Alacracity” at my home, although that is the name of the vendor State Farm sent in a fraudulent “‘ confirmation of voluntary participation’ in their program.
I never agreed to have State Farm contact AEG for for a “mold clearance report” as I was led to believe by Randy Brewer that it was all out of my hands in order for policy coverage to be applied. Had I known that AEG’s primary function, as it has been exhibited throughout
this litgiaton, as “litigation support” —I would have objected to the clear and obvious CONFLICT OF INTEREST AND APPEARANCE OF RACKETEERING that seems to equate to a Hollywood style “fixer” in mob movies.
It’s unfortunate, or fortunate, depending on perspective, that Booth LLP would again attempt to bury Plaintiff with abusive and harassing discovery knowing TAC responses are due, which has been a pattern of discovery abuse evident to all co-defendants, but concealed from the Court.
Additional responses follow, and it is noted that you refuse to extend response time for any of it. IDC request will follow once all other time sensitive responses have filed.
In Pro Per
Disabled American Boomer Female Policy Holder
Linda Ayres vs State Farm et al
CIV SB 2106284
PO BOX 835
Yucca Valley CA 92286
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