HARMON'S CLAIM AGAINST AYABE, CHONG ET AL.

Bobby N. Harmon, CPCU, ARM

10951 Southgate Manor Dr. #4 Tel No. (502) 964-0694

Louisville, Kentucky 40229-1651

September 18, 2004

VIA fax @ (808) 526-3491

Mr. Sidney K. Ayabe

Ayabe Chong Nishimoto Sia & Nakamura

1001 Bishop Street

Suite 2500, Pauahi Tower

Honolulu, HI 96813

RE: Notice of Claim Against Ayabe Chong Nishimoto Sia & Nakamura, et al.

Dear Mr. Ayabe:

Based upon new evidence disclosed in Arbitration Case No. 74 166 00491 03 JAFA, Mary Lou Woo vs. Bobby N. Harmon, I am hereby advising you of new counts of fraud and racketeering involving the claims that I previously reported to your firm in my letters dated June 24, July 11, August 3, and August 16, 2002.

In the letter dated August 16, 2002, addressed to you, I wrote:

“This is to acknowledge receipt of your letter dated August 6, 2002, in which you advised that my Notice of Claim dated June 24, 2002 had been sent to your insurance carrier, and that you had been instructed by St. Paul Insurance Company to inform me that they acknowledged receipt of my claim. You also advised that you would forward a copy of my letter of August 3, 2002, to them.

“This is also to inform you that on August 10^th, I sent a letter to Matt A. Tsukazaki, of Katz, Fonseca, Jaffe, Moore & Hetherington. Since I made reference to your firm in this letter, I had intended to send you a copy; however, it appears I overlooked this so I am sending it to you at this time. Please forward a copy of this letter, also, to the St. Paul Insurance Company. Thank you.”

For your information, the St. Paul Insurance Company has never responded to any of my Notice of Claim letters, which is highly unusual and unprofessional for an insurance company the size and stature of the St. Paul. As a consequence, I now find it necessary to send this follow-up notice, and information regarding further incidents of conspiracy and fraud, to your attention rather than to St. Paul Insurance Company’s independent claims adjuster.

The new information to which I refer is contained in Steven Guttman’s Declaration in Support of Claimant’s Request for Fees and Costs, received on September 2, 2004. I refer you to the following entry in Mr. Guttman’s time-sheets which were attached as Exhibit A to his Declaration:

02/26/04

WI RVW LTRS FROM ATTYS TSUKAZAKI & LIBKUMAN

SG TC FROM ATTY RINA STONE RE JOHN MULLEN

SG REVIEW LIBKUMAN LTR (.10); TC FROM ATTY MT RE ARBITRATION ISSUES (.30)

Ronald Dale Libkuman, Esq. has the following factual connections to this claim:

> Ronald Libkuman was one of the interim trustees for Kamehameha Schools/Bishop Estate during my RICO lawsuit; was serving at the time the Settlement Agreement was signed; and may have been one of the unidentified signatories to that Agreement;

> Ronald Libkuman was the recipient of several letters in my so-called “letter-writing campaign” which was an issue in this arbitration;

> Ronald Libkuman has been named in my Claims Letters, an example of which can be found at: www.the-catbird-seat.net/Claim-KAA-7-30-2.htm;

> A short biography on KSBE’s website (1999) stated: “For the last eight years, Libkuman has been acting as an arbitrator or mediator in all types of legal disputes,” suggesting a possible connection with the American Arbitration Association and/or the arbitrator Judith Neustadter Fuqua.

> Ronald Libkuman was one of Respondent’s named Witnesses on the date of Steven Guttman’s review of his letter and the telephone call from Attorney Matt Tsukazaki regarding this arbitration.

The following information was taken from the internet at www.hid.uscourts.gov on September 17, 2004:

Ronald D. Libkuman Resume

General Information:

Age 70 (D\B 1-14-32)

Licensed to practice in Hawaii 1960

Legal Background: RDL has engaged in a litigation law practice from 1960 to 1992. ... In January 1963 RDL, and Richard Knight started the firm of Knight and Libkuman. Richard Knight passed away in January 1964 and RDL continued for a while as a sole practitioner and then as attorneys joined RDL, a firm developed which over the years became the firm of Libkuman, Ventura, Ayabe, Chong and Nishimoto....

RDL retired from the LVACN firm and became “Of Counsel” in July, 1990. From July 1990 to January, 1992 RDL completed cases in which he was involved. From about January 1992 to the present RDL has engaged exclusively in the practice of arbitrating and mediating cases of all types acting as the arbitrator or mediator....

In August, 1994 RDL and James Ventura, his longtime partner in the LVACN firm who had also become “of counsel in July, 1990", moved to an office located at Suite 200, Dillingham Transportation Building, 735 Bishop Street, Honolulu, Hawaii 96813. The relationship with the LVACN firm (now known as Ayabe, Chong, Nishimoto, Sia and Nakamura) is excellent. RDL’s practice is now limited at acting as an arbitrator or mediator in legal disputes of all types.

In February 1999 RDL became a Special Purpose Trustee (one of five Trustees) for Kamehameha Schools (formerly Kamehameha Schools\Bishop Estate) for the purpose of negotiating Internal Revenue Service claims against Kamehameha Schools. On May 7, 1999 RDL became an Interim Trustee of Kamehameha Schools along with four other Interim Trustees. This position with Kamehameha Schools ended on December 31, 2000. During this period RDL continued to act as an arbitrator and mediator in various types of legal disputes and is now back to the full time practice of arbitrating and mediating such disputes....

< END OF QUOTATION >

While the brief notes in Steven Guttman’s time sheets do not disclose any details of Ronald Libkuman’s letter, I maintain that the simple fact that Ronald Libkuman and Matt Tsukazaki had direct, undisclosed contact with Steven Guttman to discuss matters relating to the arbitration, is a severe breach of ethics and provides further evidence that the secret settlement negotiations with Kamehameha Schools and P&C Insurance Co. in my bankruptcy case were deceptive and fraught with fraud. In other words, the fraud and racketeering activities involving KSBE and P&C that I first revealed to various authorities in 1996 and 1997, and the attempts to coverup these wrongful activities, have continued to this date.

To resolve these outstanding claims, I request that you promptly forward this letter to St. Paul Insurance Company for their immediate response. I will provide them more information and documentation regarding my claims against Jeffrey Sia, Esq., and your firm, as soon as I am contacted by their authorized claims representative.

If your firm, and/or the St. Paul Insurance Company, would prefer to join with other entities against which I have similar claims outstanding, I suggest that you contact Kamehameha Schools or P&C Insurance Company to discuss the possibilities for negotiating a global settlement with all parties. I have already written to these two entities suggesting this course of action.