#StateFarmFiles – Part 3


DISCOVERY – NOVEMBER 2022

Linda Ayres vs State Farm et al – CIV SB 2106284 – PLAINTIFF RESPONSE TO AEG REQUEST FOR FORM INTERROGATORIES – GENERAL – SET THREE AND GENERAL STATEMENT AND DECLARATION OF PLAINTIFF

LINDA AYRES PLAINTIFF RESPONSE TO AEG Form Interrogatories SET 3 – 11 14 2022 (4)

https://tinyurl.com/AEG-EXHIBITS101-11-14-2022
https://tinyurl.com/AEGlitigationSupportMoldAQ

From: Linda Ayres <lindaayres311@gmail.com>
Date: Mon, Nov 14, 2022 at 3:39 AM
Subject: Linda Ayres vs State Farm et al – CIV SB 2106284 – PLAINTIFF RESPONSE TO AEG REQUEST FOR FORM INTERROGATORIES – GENERAL – SET THREE AND GENERAL STATEMENT AND DECLARATION OF PLAINTIFF
To: John Meno  , Brendan Fogarty  , German Marcucci  >, Sicari, Dominique   Dominic Campodonico  >, Gabriel Hedrick  
Cc: Linda Ayres <lindaayres311@gmail.com>

 

 
Gentlemen,
 
More responses to AEG.  Please let me know if you have any questions.
 
As soon as I file all TAC objections, I will know exactly what to succinctly request of the Court in the request for the IDC – Informal Discovery Conference. 
 
State Farm and AEG have both refused and failed to produce claim file documents prior to litigation and in response to discovery.  The conference will also address the objections to my discovery responses, I don’t seem to have a copy of the Contractor Connection responses to Paul Davis Restoration, and I recently reviewed — was it about 6″ of demands from Contractor Connection to Paul Davis Restoration.  
 
Please do note that one of the links indicates that ALL OF CONTRACTORS IN THE NON-VOLUNTARY PREMIER SERVICES program PROVIDE A FIVE YEAR GUARANTEE.  My participation was by deception and fraud that it was required for  policy coverage, and Alacracity was allegedly the vendor for my claim, effective late February 2019.  The work was not guaranteed at my home, and in fact, a $10,000 loss was turned into a catastrophic loss with life threatening toxic exposure, costing me to date over $125,000 out of pocket, in addition to the initial demo, buildback, loss of use, and $8k for my household good that State Farm paid another $101,000 for, and we still do not have a mold clearance, nor an estimate for what it will take to return my home and health to preloss condition. 
 
The more times I tell the facts, the more succinct I seem to gete.
 
Theme right now is that STATE FARM DID NOT DENY MY CLAIM FOR WIND PERIL, ROOF LESS AND CONSEQUENT WATER DAMAGE, SO WHAT CAUSED CATASTROPHIC DAMAGE AND LIFE-THREATENING ILLNESS.
 
AEG defense counsel does indeed seem to be moving forward the position of Litigation Support, and that seems to be quite a discovery in that Randy Brewer, State Farm initial adjuster,  allegedly organized AEG, in supreme conflict of interest, knowing full well the damage done by the 40 days of water intrusion.  Randy told me a few times when I asked  him to please elevate the file to the legal department because of the damage being done in the first weeks and the failures to mitigate damage – that  he could not elevate it to legal and the only time legal would get involved is in subrogation and he advised, ‘that won’t  help you with what they have done.”
 
So, everybody knows that I had a small $5,000 roof replacement claim, with loss of use and some  household goods losses on 2/2/2019.   STATE FARM adjusters and vendors increased the damages, and AEG turned the $101,000 mess into a $10 million dollar lawsuit, and who knows how many billable lawyer hours.
 
We may not settle, and a jury may not grant a NUCLEAR VERDICT, but I can rest assured that I have warned my fellow Americans about the diabolical conduct of the carrier and it’s assigned vendor, and criminal threats throughout the “litigation support” process.  The former State Farm legal counsel, as AEG counsel reminded me on a phone call, when I was asked, “Which law firm is remaining silent and doing nothing?”  
 
I said, “I dunno, there’s too many, I can’t keep track without looking thru my piles of paper.”  The lawyer then said, “Let me  help you  out. It’s State Farm. Why do you think that is? ”  I said, “I dunno.  I figured you’re the attack lawyer, and they’re just watching and supporting”.
 
All these files have been previously produced, and AEG counsel also deceived the Court that I did not produce and I was even sanctioned thousands of dollars in the guerrilla lawfare.
 
I have not published the medical pictures publicly, but at this point, I believe my fellow Americans also deserve to see what can happen when they are insured by State Farm, the claim is not denied, and reports are obtained to cover up  the negligence (gross or criminal) that might poison the occupants, willfully, maliciously, and criminally.
 
The 4 emails are also at the end of the exhibits, and I guess I will have to get a subpoena to get the rest of the story on who sent AEG to my home, what was the agreement, why was the report so egreiously flawed, did AEG really tell Joey Camisso, one of the interim adjusters that the August 2019 AEG report was “all clear” — further evidencing conspiracy and criminal cover up with intent to cause illness and death, with a thin veil of plausible deniabiilty.
 
I don’t know what else to tell you other than I am preparing for trial, and as AEG counsel also recomended, I am working on my TED Talk … PRELIMINARY TITLE IS  HOW TO SURVIVE A COVERED STATE FARM LOSS …  
 
Cordially,
 
Linda Ayres
 
 
 

———- Forwarded message ———
From: Linda Ayres <litigation.statefarm.aeg@gmail.com>
Date: Mon, Nov 14, 2022 at 3:09 AM
Subject: Linda Ayres vs State Farm et al – CIV SB 2106284 – PLAINTIFF RESPONSE TO AEG REQUEST FOR FORM INTERROGATORIES – GENERAL – SET THREE AND GENERAL STATEMENT AND DECLARATION OF PLAINTIFF
To: Hillary Booth  
Cc: Linda Ayres <litigation.statefarm.aeg@gmail.com>


 
Ms Booth and All Defense Counsels via separate email – 
 
 
Attached is Plaintiff’s response to AEG Form Interrogatories – Set Three. 
Of course, counsel knows that it has already received these documents, in December 2021 and in the repetitive requests for production of documents,
The tactics of continued burdensome and abusive discovery continues as a pattern of practice, as this set arrived the night before the most recent hearing.
 

It cannot be stated too often that STATE FARM DID NOT DENY THE CLAIM FOR WIND PERIL, ROOF LOSS AND CONSEQUENT WATER DAMAGE.  
 
A jury will draw conclusions of who and what caused the catastrophic losses and toxic exposure.
 
It will likely be of interest to the jury that the initial vendors considered the 2/2/2019 loss to be a small loss, and in fact, that the loss of use was projected to be less than a week to ten days, initially.  Hotel stay was extended a week at a time, as it was an “insignificant” loss. small in comparison to other jobs PDR as allegedly working on.
 
It appears, with the coverup of the factors that caused unabated and unremediated and only partially demolished water damaged materials including  but not limited to approximately 40 days of additional water intrusion that destroyed not only the
home, but contents (pack out was not done until approximately 10 days of  unabated water intrusion – 65% of the roof WAS GONE. – it appears that the conspiracy, combined with the recently discovered services of LITIGATION SUPPORT provided by AEG, is greatly suspected. 
 
EVERYTHING GOT RAINED ON…. INSIDE THE HOUSE.  ROOF ONLY EXISTED OVER THE KITCHEN.  POLICY COVERAGE FOR CONTENTS WAS APPROXIMATELY $145,000 AND STATE FARM PAID $8,000.
 
DIAGRAMS ARE AGAIN PROVIDED IN THE PRODUCTION OF DOCUMENTS, SHOWING THE KNOWN AND IDENTIFIED WATER SATURATED MATERIALS, THAT WERE APPARENTLY MEANINGLESS TO THE AEG INSPECTION AND LAB TEAMS.
 
At one point, AEG counsel suggested, as a comment on a public blog, that Plaintiff should also include the Lab in the lawsuit.  The March 19, 2019 testing was analyzed by EMLAB P & K, and the August 22, 2019 testing was analyzed by AIH.
A subsequent inspection, June 23, 2020, by Mold Inspection Sciences, was also analyzed by EMLAB & PK, that same Lab that did the initial analysis on the AEG 3/19/2019 report.  Does that suggest to your experts that the failures of the AEG March 2019 report were due to the inspectors, or the lab?  LA TESTING did 3 testing analyses on 11/13/19, 2/21/20 and 3/17/20 — each showing extreme levels of dangerous microbial growth.  All defendants, including AEG, report on their website of the necessity of urgency in handling water damage, and dire consequences when that is not done.  
 
Yet AEG stands by it’s report of March 2019 that State Farm adjusters in Arizona used to authorize build back, over unremediated known water damaged/water saturated walls, insulation and roof sheathing???  Or is AEG contending that the failures were with the labs used by AEG — both EMLAB & PK and AIH??
 
If AEG will be counter suing the labs, please advise at your earliest convenience.  It might be possible that other defendants, and possibly the plaintiff, might want to include EMLAB & PK in litigation.
 
 
AIH identified toxic mold, but it seemed to skew the result, or the AEG lab manipulated the AIH results, to show them as “unacceptable*” and when asked, AEG lab suggested that that surfaces be cleaned and hepa vacuum, and recontacted if there were further problems.
That alone smacks of negligence or fraud, I’m sure your experts may agree.  AEG allegedly reported to State Farm agent, Joey Cammiso, that the August 2019 report showed “all clear” which was also false.  Records may clarify, when subpoenaed.
 
 
The $10,000 surface cleaning recommended protocol, amended due to questions on the asterisks after unacceptable levels, was also made by another State Farm pool vendor.  
Subsequent inspections further refuted even the second AEG report – and the November 13, 2019 report WAS AUTHORIZED BY STATE FARM field adjuster.
 
Refusal of counsel to disclose communications between defendants that caused the delays and inadequate environmental testing continues to obstruct justice and will be referenced in the IDC – request for Informal Discovery Conference.
 
 
Based on the mold clearance report requested of American Environmental Group by State Farm Arizona claims office, authorization to build back the house after approximately 40 days of water intrusion,
with 65% of the roof gone, facilitating unabated water intrusion for weeks, was made by State Farm, based on the AEG report.  
 
The  AEG report was refuted by multiple reports after the March 2019 reported, and the August 2019 AEG report was also refuted by companies not compromised by being a part of the
State Farm vendor pool, and none of which offered litigation support, which not only did AEG apparently provide, but continues to do so in litigation, evidenced by the compliance of State Farm
counsel, and others, to remain silent and supportive of the lawfare and abuses of the self-represented victim of the conspiracy by the remaining defendants to coverup the negligence organized
by the State Farm desk adjusters in Arizona that resulted in catastrophic and life threatening losses and obscene litigation.
 
The State Farm “data dump” that you object to receiving is again included, as it is the only set of documents State Farm has provided, like AEG, in it’s discovery objections.
In it you will again see the 4 extremely relevant emails regarding the request for “mold clearance” made by State Farm and organized with State Farm, which is a monumental
factor in the catastrophic losses sustained by the policy holder because of State Farm adjusters, adjuster representatives, and assigned vendors, of which AEG was the last and final one.
 
If necessary, the Clerk will be requested to subpoena the records of that series of communications that caused the losses and life threatening toxic exposure.
 
Some of the answers may seem repetitive, but so are the requests for admission, and production of documents.   Hopefully the reiteration will  help  the newly assigned lawyers to get up to speed and assist the other co-defendants in seeing
the actual culpability caused by the AEG report provided to State Farm Arizona adjusters in response to the need for a MOLD CLEARANCE REPORT in March 2019.
 
Roy Paynter has a history, at least per Youtube in his deposition, of intentionally harming policyholders, knowing the carrier’s duty to help policyholders,  while protecting incompetent or unscrupulous adjusters and likely vendors.  He is expected to be deposed in January 2023, along with Randy Brewer and whoever else spoke with AEG — including but not limited to Joey Cammisso who was allegedly given false info from AEG that the August 2019 inspection was “all clear”
 
The report by AEG also caused State Farm adjusters to refuse to provide me with shelter once the contamination was discovered, and allegedly State Farm even told Temporary Accommodations they could not help me find shelter or give me any information on 
putting an RV on my property so that I could be safe.  So I had to buy one.  
 
I believe it was Contractor Connection that suggested discovery may not be complete till July 2023 –I suggest it may be  longer if AEG and State Farm continue to object, requiring subpoenas for basic information.  
I don’t believe I have received the Contractor Connection discovery response to Paul Davis Restoration yet, either.
 
Cordially,

Linda Ayres 
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
 
ATTACHMENTS FILE LINKS: 

 

Linda Ayres
In Pro Per Plaintiff
Disabled American Female Boomer
State Farm Homeowners Policy Holder
Linda Ayres vs State Farm et al  – CIV SB 2106284
PO BOX 835
Yucca Valley CA 92286

2 responses to “#StateFarmFiles – Part 3”

  1. When #litigationintimidation is directed like a weapon targetting a self-represented plaintiff’s well documented disabilities, it’s beyond moral turpitude, imho.

    Doing my best to respond to the ADMISSIONS AND DISCOVERY DEMANDS THAT WERE MADE AFTER THE EXPARTE CIRCUS HEARINGS OF NOVEMBER AND THE COURT RULINGS OF DECEMBER…

    Like mainstream media, some defense firms are hell bent on distractions rather than truth and justice. Oh well…. A JURY OF PEERS WILL WORK IT OUT.

    THE HEART OF AMERICA IS SOUND…

    #WhoYaGonnaCall

    Homeowner Insurer Fraud and Racketeering: How to Get Help when DIY is just too hard….

    Homeowner Insurer Fraud and Racketeering: How to Get Help when DIY is just too hard….

    Remember remember…. #WeAreTheMediaNow
    #StandUp #SpeakYourTruth and #BePolite

    Like

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