Bad Faith Claim against St. Paul Fire and Marine Insurance Co.

Bobby N. Harmon, CPCU, ARM

November 9, 2006

VIA Fax: 808-521-9648

& e-mail: dlouie@rlhlaw.com

David M. Louie, Esq.

Roeca, Louie & Hiraoka, LLP

900 Davis Pacific Center

841 Bishop Street

Honolulu, HI 96813-3917

Re: Bad Faith Claim Against St. Paul Travelers Company, Inc., et al.

Claimant: Bobby N. Harmon

Insurer: St. Paul Fire and Marine Insurance Company

Insured: Ayabe, Chong, Nishimoto, Sia & Nakamura

Claim Number: DR00601442 22H002

Tracking Number: JHO1511

Date of Loss: June 24, 2002

NAIC Number: 3548-24767

DOI File Number: Unknown

Dear Mr. Louie:

This responds to your letter of October 30, 2006, in which you state:

“I am in receipt of your letter dated October 5, 2006, which you sent by email. I have previously responded to your inquiries by my letter dated October 3, 2006, a copy of which is enclosed. In that letter, I clearly stated that our law firm represents St. Paul Travelers (“St. Paul”) with respect to your claims of bad faith against St. Paul regarding an alleged “claim” you made against Ayabe, Chong, Nishimoto, Sia & Nakamura. I also stated in that letter that my law firm does not represent Ayabe Chong at this point in time, especially with respect to claims that you may seek to assert against other parties.”

For the record, my letter of October 5, 2006, was in response to your letter of September 22^nd, as I had not yet received your letter of October 3^rd. And, while your letter of October 3^rd may have included information about who you are representing, your current letter of October 30^th does not address, or answer, my bad faith claims against your principal, St. Paul Travelers, which I described in my October 5^th letter. Therefore, I am claiming that this non-response to the claims issues presented in that letter is yet another act of bad faith by the St. Paul Travelers Insurance Company.

Furthermore, since your office does NOT represent Ayabe, Chong, Nishimoto, Sia & Nakamura for my claims of fraud, racketeering, bad faith, etc., against that firm, then just who is representing them? And, why has no one from the St. Paul Travelers contacted me regarding the adjustment of those claims? This simple fact that the St. Paul Travelers has not even begun the normal process of adjusting my claims against their client, even after my follow-up claims letters and complaints to the Office of the Hawaii Insurance Commissioner and the National Association of Insurance Commissioners, is further evidence of bad faith on the part of the St. Paul Travelers, which you are now expected to address as their legal representative.

Your prompt response to these questions, and to the remaining unanswered claims issues addressed in my October 5, 2006 letter, is respectfully requested.

Very truly yours,

Bobby N. Harmon, CPCU, ARM

cc: Jeffrey H.K. Sia, Esq., Ayabe Chong Nishimoto... (Jeff.Sia@excite.com)

Kenneth Hipp, Esq., Marr Hipp Jones & Wang (khipp@marrhipp.com)

Steven Jay Katzman, Office of the U.S. Trustee (via fax: 619-557-5339)

Curtis Ching, Gayle Lau and James Nicholson, Office of the U.S. Trustee,

c/o Steven Guttman, Esq., Kessner Duca Umabayashi, et al. (sguttman@kdubm.com)

Gerard Jervis, Lokelani Lindsey, Henry Peters, Oswald Stender, and Richard Wong, c/o Kenneth Hipp, Esq., Marr Hipp Jones & Wang (khipp@marrhipp.com)

Governor Linda Lingle (via fax: 808-586-0006)

Henry Paulson, U.S. Treasury Secretary (via fax: 202-622-6415)

Janet Hughes, Internal Revenue Service (via fax: 720-956-4564)

Alberto Gonzales, U.S. Attorney General (AskDOJ@usdoj.gov)