OBJECTIONS EXPARTE MEDICAL AND MORE… OH MY
WHEN IS IT OK TO FAN BLACKMOLD???
SOMETHING IS TERRIBLY TERRIBLY WRONG WITH INSURANCE IN AMERICA, ISN’T IT?
WHEN STATE FARM ACCEPTS A CLAIM, DESTROYS YOUR PROPERTY AND POISONS YOU…
EXPECT GUERILLA LAWFARE WHEN THEY TELL YOU TO LITIGATE…
The teams of premier services vendors they hired, they will surely damage and destroy your home, also have teams of lawyers that will reak havoc in what remains of your world.
#AskStateFarmWhy they target 5 year olds and old retired white women with disabilities…. and ask about those indemnity clauses and at what point they throw their vendors under the bus.
It’s pretty spooky when you tell people that people have told you you’re blacklisted by the legal community and those people nod and say they know what you mean, and probably more than that.
ARE NO ETHICS AMONGST DEFENSE LAWYERS? Like one FBI agent once said to me about insurance corruption, HOW CAN THEY SLEEP AT NIGHT.
Today I would to shrug again and say, ‘HISSING DEMONS DON’T SLEEP AT NIGHT”
From: Linda Ayres <lindaayres311@gmail.com>
Date: Mon, Sep 26, 2022 at 5:11 PM
Subject: 1 of 2 ExParte motion Objection – Linda Ayres Vs State Farm et al
To: Hillary Booth Dominic Campodonico , Gabriel Hedrick , German Marcucci Sicari, Dominique , Michael McGuire Dominique Tomaino John Meno , Linda Ayres <lindaayres311@gmail.com>
Dear Counsels:
Attached is the Opposition to American Environmental Group (AEG) Motion for Dismissng the 4th, 6th and 9th Causes of Action….. Memorandum of Points and Authorities, Declaration of Linda Ayres and proof of service. Exhibits follow in next email.
I understand that most of you will be attending remotely.
I suggest that the rest of us schedule meet and confer to move discovery forward, and schedule depositions starting with State Farm adjusters and adjuster managers. A group call to plan for discovery and deposition would be appropriate but I am also open to one on one Meet and Confers.
We also need to discuss updating service lists and immediately cease and desist copying all settled defendants. There is no reason for them to be copied and it certainly displays a continued breach of confidentiality amongst co-defendants, as we experienced severely earlier this year and late last year. I have no idea who J Meno is, or who B Forgarty is, nor do I know if they are reinforcements at State Farm defense, or replacements. I am awaiting word.
I believe we need an in chamber hearing with the Judge, with all of us in person, to ensure that AEG does not do for the next few years what they have done for the past two. The burdens on the Court, on co-defendants and the Plaintiff are, in my humble opinion, absolutely unconscionable. You may agree as you read this and see the exhibits
I will be attending the hearing in person.
Cordially,
Linda Ayres
tel/text 760 368 5243
—
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
Search for latest: tinyurl.com/LindaAyresVsStateFarmEtAl-BING
PO BOX 835
Yucca Valley CA 92286
ALL NUCLEAR REACTORS LEAK ALL THE TIME, SOME MORE THAN OTHERS, ON PURPOSE.
1,946 Known Radioactive Isotopes
#DodgeTheRads
From: Linda Ayres <lindaayres311@gmail.com>
Sent: Saturday, October 8, 2022 1:55 PM
To: Hillary Booth Dominic Campodonico ; Gabriel Hedrick ; Sicari, Dominique German Marcucci ; Michael McGuire ; Dominique Tomaino John Meno
Cc: Linda Ayres <lindaayres311@gmail.com>; litigation.statefarm.aeg@gmail.com
Subject: LINDA AYRES VS STATE FARM ET AL – OCTOBER 18, 2022 HEARING PREPARATION & copy of email sent to all settled defendant’s counsels
Dear Counsels:
So, I understand that discovery responses from Contractor Connection and State Farm are due to Paul Davis Restoration shortly. Meets and Confers in light of current chaos seem appropriate. I am available and willing. Let this be an introduction of my continued position, and a recap to the new folks.
Let’s be very clear that State Farm unlawfully and repeatedly told this policy holder that insurance coverage was only available if the assigned Premier Services/Preferred Vendors were used, and State Farm later colluded with American Environmental group on obtaining a “mold clearance” that was not a clearance at all. Contractor Connection assigned Paul Davis Restoration as the General Contractor, who authorized one of the settled defendants to do the dry out and demolition. Then they both lied and said PDR was only hired for packout, after 10 days of water contamination.
Industry workers suggest that “pack outs” are the sweet fast money; it’s not even close to right that PDR would take that piece of the work, and blame the settled defendant causing delays in demolition — when the vendor who appeared to be a PDR subcontractor called it as BS and clearly stated that demo could not be completed until the roof was replaced. State Farm Adjusters, Paul Davis Restoration and Contractor connection caused those delays, but blamed the policy holder for refusing to be extorted for cash for a “fast roof.” As a consequence of policy holder’s refusal to participate in an apparent extreme insurer fraud scam, the consequeces were catastrophic damage to her home, and life threatening illness.
Randy Brewer of State Farm repeatedly told the policyholder/plaintiff that “nobody likes the State Farm Preferred Vendor program, but we’re stuck with it” in response to multiple requests for “authorization” to replace the assigned vendors. The cover up began with false Premier Services ‘welcome’ email in early March 2019. The roof blew off 2/2/2019. The cover up continued when State Farm contacted American Environmental group, apparently as “litigation support” for the negligence and fraud clearly already committed by multiple parties, and covered up.
The rest is in the SAC and TAC. The bottom line is that your clients caused catastrophic damage to my home, knowingly and intentionally and caused toxic exposure and life threatening illness….
Let’s also be clear that some members of the legal community have clearly declined to represent me because I “fit the profile” of a State Farm targeted individual– elderly, disabled, and female.
I would hope that after you read this, and review the facts again, you will do right by me.
I still don’t know if State Farm legal counsel has been replaced or reinforced. Perhaps on the 18th of October the Court can determine the latest service lists, and rule on continued copying by defendants or settled co-defendants.
I just received a notice of more legal chicanery from Booth LLP in the form of NOTICE OF FAILURE TO OPPOSE MOTION TO COMPEL RESPONSES… Ms Booth and I worked zealously to resolve that matter, and she told me it would be taken off calendar. She either forgot or lied or just failed to communicate with Mr Greene.
Are there any other issues we might individually or as a group meet and confer on prior to the multiple matters to be heard on October 18, 2022? I would expect the Court to expect civility and maturity in handling issues, but maybe such deception and childishness is acceptable?
In multiple Meet and Confers with Ms Booth, on the phone and via email, all those matters were resolved, and she agreed to take that hearing about the final piece of abusive discovery off calendar. Apparently, there may be a continuous communication breakdown between Ms Booth, Mr Greene and their staff.
That happened before, too, when Ms Booth blamed the Court for not taking a hearing off calendar, and all of us had to appeared again. I appeared remotely, and listened to Mr Greene tell the Judge that I wouldn’t be there… he seemed surprised that I was. This pattern of practice must be curbed if we are ever to finalize discovery and depositions.
I will ask Judge Foster to intervene and appoint a Master or somebody to supervise Boothe and save us all from more legal chicanery and disrespect for the Court. That requires more research, as I don’t know exactly what the Courts can do to interrupt such constant disrespect for the Court and the Rule of Law.
I do know that I am certainly entitled to Accommodations for my disabilities, as agreed to by the Court upon presentation of my medical records and a very specific set of ADA accommodation requests. Trickery by defense counsel, in light of disclosed disabilities, is reprehensible, at best.
Let it be understood that I do understand that Booth has no defense for their client, so guerrilla lawfare and professional misconduct seems their only avenue.
None of us would likely have ended up in Court if State Farm and AEG had not colluded to create a toxic environment and premature, inappropriate fast build back, that would prove to be life threatening. The harm done by the other defendants would have been much less substantial, had there been a proper mold clearance. Check any of the defendant’s websites regarding water damage, dry out, mold clearances and remediation. This is clearly criminal intent.
The bottom line is that State Farm conferred with American Environmental Group directly, without knowledge of or participation by policy holder/plaintiff regarding a “Mold Clearance” after more than 40 days of extreme water intrusion through a roofless house, that was apparently only partially demolished and not at all remediated — all under the supervision of Randy Brewer, State Farm assigned seasoned adjuster, and approved by notorious “Adjuster Team Manager” Roy Payntner.
Whoever made the decision on the inappropriate “mold clearance report” that was produced between State Farm and AEG, – whether it was Randy Brewer, Roy Paynter or someone else, in collusion with American Environmental Group – those parties are highly responsible for the catastrophic and life threatening losses. State Farm has unlawfully refused, since 2019, to provide me with the complete claims file, and even in discovery they refused to provide missing pieces of correspondence between State Farm, ServPro, PDR and AEG and ContractorConnection.
The cover ups makes this appear to belong in criminal court, Criminal Federal Court for RICO indictments.
In full transparency, below is an email I sent to all dismissed counsel, and they apparently don’t care if we revert to the SAC in regards to their name appearing. They wish we would all stop copying them on matters that no longer concern them. I wanted to protect myself from any false allegations of breach of confidentiality, in the event we revert to SAC, and to invite their input. They don’t care.
The SAC replaces/reinstates the inadvertently omitted Elder and Disability financial abuse, and puts the $10 million number back in, and criminal courts may end up dealing with the RICO matters. I’m advised that civil litigation will go on hold, in that event, “back burner” so to speak. That’s ok with me. I’m in this also for My Fellow Americans, as you probably realize by now?
Ms Booth tried to bamboozle me that in the AEG answer, they would re-respond to what the Court already ruled on, so that that I should accept her unacceptable settlement offer. She appeared to get very angry when I told her that Mr Greene attempted the same bamboozlement, in front of the Judge, and the Judge clarified to him. Ms Booth huffed about that, cut the call short saying she would have to check the file, and the next thing I knew she failed to answer in the multi-extended deadline, and they started with the ExParte burdens again. Booth Managing Partner has said more than once that she doesn’t care if this ever settles, and we all know that’s true.
They apparently don’t want your clients to settle either. They interfered with settlement discussions earlier this year, boasting of breaches of confidentiality, yet now they claim they can’t and don’t care about any other defendants. I suggested they might have a cross complaint against State Farm, if State Farm withheld important information when the “mold clearance report” discussions were compromised.
Here’s the most recent video — it illustrates and highlights the severe threats I have experienced from Booth LLP, and they continue to be unacceptable and deserving of sanctions. It’s short – 3:21 minutes — we’ll find a way to get it submitted as evidence for trial.
Visual presentations help me communicate, as my brain can retain images longer/better than word threads, a loss of executive function disability, much like not having a mental copy and paste function and clipboard, further evidenced in some repetition and lack of succinctness.
WHEN THEY DON’T CHANGE THE LAWFARE PLAYBOOK Linda Ayres vs State Farm et al
They led me to believe their names had to be removed as part of the settlement agreement, which is why I had to work so hard to remove references from the TAC, after timely responding to the remnants of supplemental responses to the barrage of AEG discovery.
Please note that, like last year, when Booth LLP attempted to ask the Court to Violate my First Amendment rights, and justice prevailed in that ExParte Hearing, as in the recent one. Coincidentally, last year, as this year, my LinkedIn account with mountains of posts on these matters was again terminated and again, my Social Security income stream is being threatened.
Once in a lawsuit, ok, maybe it’s plausible. The same scene playing out AGAIN -certainly seems to reinforce RICO allegations, and seems to further implicate Social Security Administration collusion with the insurance cartels, or at least with insurance defense counsels to obstruct justice.
I will ask the Judge to intervene as the childishness and trickery and bad faith that continues to be perpetuated via Booth LLP continues to be burdensome to the Court, to all counsel and to the self-represented plaintiff.
As mentioned, in light of the continued abuses by Booth LLP, and the collective inability to settle amicably, any numbers left on the table have doubled until October 18, 2022… and perhaps the Judge can order some sort of in Chamber meeting so that civility can be restored and BOOTH LLP can be reined in. I know some of you consider them to be running this litigation “like a train wreck” and I think, based on the latest from them, that train has gone off the track.
My official objections to Booth latest vexatious matter will follow… this is the gist of it, and I will do my utmost to put it on the proper forms and be prepared with a video and oral opposition to any rulings till we figure out which Amended Complaint we are working with, and re-set, in clear language with dates, due dates of whatever is next.
I think we need at least another 9 months for discovery and as Ms Booth suggested, further depositions are moot till we figure out what amendment we are working on. Before Christmas, as I advised State Farm defense counsel, I do want to depose State Farm adjusters, Randy Brewer, Linda Holloway Cox and team manager, Roy Paynter.
My blog on that might (or might not) be of interest to you.
WHAT QUESTIONS WOULD YOU ASK THE ADJUSTERS INVOLVED IN AN INSURANCE SCAM THAT CAUSED LIFE THREATENING ILLNESS AND CATASTROPHIC PROPERTY LOSSES? Asking for A Friend
DEFENSE TEAMS SAY IT’S MY MOVE? HERE IT IS. SEE YOU TUESDAY, with objections and requests for sanctions and conversion to COMPLEX LITIGATION to protect the Court from further chicanery and costly burdens on the Court, Co-Defendants and Plaintiff with Disabilities and accommodations requested.
Cordially,
Linda Ayres
tel/text 760 368 5243
——— Forwarded message ———
From: Linda Ayres <lindaayres311@gmail.com>
Date: Wed, Sep 28, 2022 at 3:03 PM
Subject: ALERT !!! 1 of 2 ExParte motion Objection – Linda Ayres Vs State Farm et al – COURT DENIED MOTIONS WITHOUT PREJUDICE – SERVPRO ALSO NAMED
To: [ settled defendant’s legal counsel ]
To: COUNSEL FOR SETTLED DEFENDANTS IN Linda Ayres Vs State Farm et al CIV SB 2106284 – EX-PARTE HEARING RULING – RESPONSE REQUIRED
Dear All Counsel for Settled Claims in the Above Case:
As several of your firms are still repeatedly copied by existing Defendants on court and other matters, most of you know that there was an Ex Parte hearing yesterday, September 27, 2022 on this matter. As in all ex-parte attacks to date, I prevailed again. The chicanery and gaslighting is accelerating by defense counsel, as are the threats.
This time, the attack includes your clients. You may recognize the pattern of practice by defense counsel. Please see how it may impact your clients below.
I trust this email finds you well. If I do not hear back from you at lindaayres311@gmail.com or tel/text at 760 368 5243 by or before October 9, 2022, I will consider this as full and complete fulfillment of any possible obligations, known or unknown, I may or may not have relative to alerting counsel for settled defendants of such incidents, per our settlement agreements regarding confidentiality and any adverse actions from earlier this year.
SERVPRO INDUSTRIES INC. was named in the Exparte Motion. Desert Valley Restoration dba Paul Davis Restoration and Remodeling of Greater Palm Springs was omitted from the EX-PARTE MOTION FOR DISMISSING 4TH, 6TH AND 9TH CAUSES OF ACTION – Maybe that’s not a big deal? I would suspect that ServPro would not not pleased to know this. Several of your firms were also copied by opposing counsels. State Farm has either replacement attorneys or reinforcements, in light of notices of remote attendance and other communications.
Without your intervention, our confidentiality and settlement agreements may be breached by vexatious motions and lawfare, of the kind rampant throughout this litigation since early 2021. You have witnessed it; I have experienced it, and the Courts have been repeatedly overburdened. Now, it seems that your clients are the targets, with a concerted effort to keep the Second Amended Complaint and dismiss the TAC.
Only one of the five remaining defendant’s defense counsel failed and refused to respond to the TAC, after requesting extensions and initiating more bad-faith settlement discussions, then using the tired tactic of ex-parte hearing for falsely alleging that the Plaintiff did not file the Third Amended Complaint, when it was properly served, and after multiple meet and confer sessions. Meet and confer was aborted by counsel once it became evident that they did not get to respond to all Causes of Actions, previously ruled on.
The evidence clearly shows that any reasonable person would understand that the TAC due date, after 3 additional pages of conversation transcripts, was included in the July 6, 2022 due dates with the myriad of other dates. That the NOR did not include a date, nor did the Portal Notes is also evidence, and that counsels did not respond to confirmation by Plaintiff of the 7/6/2022 due date that would be met, seems to be an issue of civility.
Opposing counsel responses are only for those “sustained with leave to amend” and Defense Counsel attempted to badger self-represented plaintiff into a settlement with threats that even the previously ruled on Causes of Action were be ruled on again, and strikes sustained. In Court yesterday, Plaintiff advised the Judge that defendant claims the responses due 9/20/2022 but were not filed by counsel. Plaintiff suggested that Court give defense counsel 48 hours to produce them. The suggestion was denied.
The TAC will be discussed on 10/18/22 Trial Setting Conference hearing… the 5th or 6th attempt to set a trial date.
When counsel was advised that associate counsel had attempted the same chicanery and the Judged clarified to counsel, shortly thereafter the Ex-Parte hearing notice for dismissals was improperly served (so I didn’t get a copy, but some of you did). After further communication, counsel had the September 22, 2022 hearing continued teo September 27, 2022. My objections are attached, for your reference. If you want all the exhibits, they are filed in the Court or I can send them to you upon request.
Because the Court is still backed up with filings due to the lockdowns, and they are turning answers with notice that they may need to be refiled once Complaints are up-to-date; defense counsel attempted to have the Court order the TAC – Third Amended Complaint revoked -and reverted to the SAC, falsely claiming and alleging that it had not filed. Counsel attempted to belittle self-represented Plaintiff in multiple ways, including accusations that Meet and Confers were held with full knowledge that the TAC had not been filed, and intimidation that a court ‘receipt” is not the same as “filing” That could put your clients and their companies back on front street.That could certainly cause further chaos, burdens and costs to the Court and to the current defendants.
The objection to ExParte motions for dismissal by Plaintiff has been received by the Court, Filed in the Court in person, and blue-inked after scanning to the Court .
I worked very hard on the TAC to remove each and every reference to your settled client’s and their companies.
If the Court finds, on October 18, 2022, that the chicanery and confusion regarding the actual date of July 6, 2022 is grounds to abort the TAC, your clients will be re-tagged in the litigation, which may get more search engine results than imaginable and who knows what other chaos may occur. A Bing search has reached above 4 billion results, with these matters all over the first several pages, and it has also dropped to 2,000, on any given day. I have done my best to move documents with the TAC info.
The July 6, 2022 hearing was continued, without notice, to October 18, 2022, for unknown reasons, but the TAC was filed, in person, on the the Third floor on time and in time. The Courts are way behind, still catching up, from lock-down backlog and short staffing. I have learned that more staff is being hired, and everybody is working as hard as possible.
For your reference, attached is the Court Transcript regarding the Third Amended Complaint, settlements and other motions, stating that TAC was extended for 60 days. 3 more pages of due date discussions included moving all deadlines to July 6, 2022 hearing. The Notice of Ruling, included, was provided by defense counsel, again, without a date, but a reference to “60 days” and the Court Portal minutes also does not have a date. In the ex-parte motion, defense counsel refers to the 60 day leave to amend as “generous” which appears to be clear intimidation threat and disregard for Court provided accommodations for documented disabilities.
It was my clear and stated understanding that the TAC was due July 6, 2022, even confirmed in email to all remaining defense counsel, and that deadline was met, and all remaining defendants were properly served.
Discovery between co-defendants and cross-complaintants is also pending, due in early October 2022.
You may also recall that the months of relentless and abusive discovery, which I failed to adequately plead for protection from the Court, resulted in sanctions and demand dates to be met prior to the TAC filing, which I met. I did secure Court approval for a specially designated email address for communication, in light of the multiple emails sent every day for months, combined with actions perceived as threatening cyberstalking. Defense counsel says the special protections are for her staff, not for this Plaintiff.
You may also recall that in 2021, defense counsel similarly requested an Ex Parte Hearing, that time, a request for the Court to Violate my First Amendment Rights. All defense counsels were represented at that hearing, and remained silent as the Court reminded all Officers of the Court of the Constitution of the United State of America, and our First Amendment. I know that some of you were mad at me for requesting sanctions for your silence, which I deemed to be a breach of your Oath of Office, but it wasn’t personal. This September Ex-Parte vexatious motion seems to fit the pattern of abuse, burden on the Court and all others, and is conduct unbecoming an officer of the Court.
None of you are unaware of the legal chicanery, abuses and lawfare this self-represented disabled boomer has been subjected to that made discovery and litigation since 2021 burdensome, costly and mostly ineffective other than in obstructing justice. Defense counsel also, as you know, gloated that several of our settlement discussions were compromised, with discussions with that other firm, suggesting more than one instance of collusion. The continued copying of many of you on litigation matters by defense counsels is also, again, suspicious, at best.
For the record, our settlement agreements, that were to be swift in February/March 2021 that did not settle til May, ran out the clock and counsel that had considered representing me, declined in June when the money for retaining was finally available. That also left little time to seek further counsel, or even find anyone to tighten up/shorten up/review TAC.
One of my goals with the TAC was to get your client’s name out of the TAC, and amend the causes of action as directed by the Court. As you clearly know, only one Defendant had rulings made by the Court, despite repeated attempts to answer by all counsels. Your extra costs of litigation are certainly attributable to such lawfare and unbecome practices.
Without your intervention, not only will certain counsel continue to run the self-represented disabled plaintiff into a sea of confusion and vexatious motions, same defense firm has now apparently targeted your clients while continuing to overburden the Courts and escalate billable hour for their own firm, and those of other defendants that have not been heard.
I will do what I can, according to our agreements, but I don’t think anything much can be done without your individual and collective immediate involvement.
There are pros and cons for the Plaintiff as to the SAC and TAC. As defense counsel was advised during meet and confer, we already have enough to go to Jury Trial…and that RICO is perhaps best argued by the State Attorney or the Attorney General’s office, particularly after this latest Ex Parte expensive time and resources. waster.
If you choose not to respond to me, this email will also serve as my notice to you of the impending adverse consequences to your client, without your intervention, and I must be held harmless from whatever may come from these lawfare tactics. They certainly do nothing toward justice and resolution.
One of you mentioned that you would “miss” my Dear All emails. That was sweet.
It was not my intention to ever have to include any of you in another one, but there are issues developing, that could compromise our agreement on confidentiality and cause backlash to your clients also.
In order to mitigate the potential damages being incited by one of the defense firms that attempted but failed to reach settlement, I am requesting your immediate involvement via written legal opinion because:
1) I feel obligated to alert you to the potential adverse consequences to your client
2) I feel obligated that I must ask for your written response for the Judge that can be provided for the Court for the next hearing, currently scheduled for October 18, 2022 in Department S22 at San Bernardino Superior Court.
Attached, in next email(s) for your consideration, is the Objections to Motions for Dismissals, the Notice of Ruling regarding TAC and other matters, Portal Minutes and actual Court Transcripts
Let me know if there is anything I can do to ensure that your clients stay out of this billable-hours marathon event.
Regards,
Linda Ayres
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
Search for latest: tinyurl.com/LindaAyresVsStateFarmEtAl-BING
PO BOX 835
Yucca Valley CA 92286
ALL NUCLEAR REACTORS LEAK ALL THE TIME, SOME MORE THAN OTHERS, ON PURPOSE.
1,946 Known Radioactive Isotopes
#DodgeTheRads
———- Forwarded message ———
From: Linda Ayres <lindaayres311@gmail.com>
Date: Tue, Sep 27, 2022 at 5:46 AM
Subject: Fwd: 1 of 2 ExParte motion Objection – Linda Ayres Vs State Farm et al
To: Dominic Campodonico < Gabriel Hedrick , Sicari, Dominique , German Marcucci , Michael McGuire , Dominique Tomaino , John Meno B Fogarty Linda Ayres <lindaayres311@gmail.com>
Cc: Hillary Booth
Dear Counsels:
I just received an email from Ms Booth at Booth LLP indicating she did not receive the opposition to request for dismissal or the first email. It does show transmitted. Weird.
The Judge may want to know if anybody else had reception issues, so if you did, please advise. Another copy attached for your convenience.
Kindly confirm if you had any issues with receiving the first, second or third emails, with attachments.
I have already forwarded a second copy to Ms Booth.
Thank you.
Cordially,
Linda Ayres
———- Forwarded message ———
From: Linda Ayres <lindaayres311@gmail.com>
Date: Mon, Sep 26, 2022 at 5:11 PM
Subject: 1 of 2 ExParte motion Objection – Linda Ayres Vs State Farm et al
To: Hillary Booth Dominic Campodonico Gabriel Hedrick , German Marcucci Sicari, Dominique Michael McGuire , Dominique Tomaino , John Meno Brendan Fogarty <litigation.statefarm.aeg@gmail.com>, Linda Ayres <lindaayres311@gmail.com>
Dear Counsels:
Attached is the Opposition to American Environmental Group (AEG) Motion for Dismissng the 4th, 6th and 9th Causes of Action….. Memorandum of Points and Authorities, Declaration of Linda Ayres and proof of service. Exhibits follow in next email.
I understand that most of you will be attending remotely.
I suggest that the rest of us schedule meet and confer to move discovery forward, and schedule depositions starting with State Farm adjusters and adjuster managers. A group call to plan for discovery and deposition would be appropriate but I am also open to one on one Meet and Confers.
We also need to discuss updating service lists and immediately cease and desist copying all settled defendants. There is no reason for them to be copied and it certainly displays a continued breach of confidentiality amongst co-defendants, as we experienced severely earlier this year and late last year. I have no idea who J Meno is, or who B Forgarty is, nor do I know if they are reinforcements at State Farm defense, or replacements. I am awaiting word.
I believe we need an in chamber hearing with the Judge, with all of us in person, to ensure that AEG does not do for the next few years what they have done for the past two. The burdens on the Court, on co-defendants and the Plaintiff are, in my humble opinion, absolutely unconscionable. You may agree as you read this and see the exhibits
I will be attending the hearing in person.
Cordially,
Linda Ayres
tel/text 760 368 5243
WARNING – GRAPHIC PHOTOS – medical related to toxic exposure – photos and lists
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