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

Bobby N. Harmon, CPCU, ARM

December 26, 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 December 20, 2006, in which you state:

“I am in receipt of your letter dated November 9, 2006, which you set by email. I have previously responded to your inquires by my letters dated September 22, 2006, October 3, 2006 and October 30, 2006. In those letters, I addressed your claims and 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. As you have stated nothing new or of substance in your recent letter, and since all of your claims are barred, both by settlement and by court order, there is really nothing to discuss further with you.

“Should you continue to send meaningless letters and diatribes in the future, please be advised that I will not be responding further, and you should simply refer to my prior letters in the event that you feel that you need a response.”

Mr. Louie, you state again that you are representing only St. Paul Travelers with respect to my claims of bad faith against St. Paul Travelers. This obviously does NOT answer the question in my November 9^th letter - if YOU are not representing Jeffery Sia, Sidney Ayabe and the law firm of Ayabe, Chong, Nishimoto, Sia & Nakamura regarding my previous claims of fraud, racketeering, bad faith, etc., against them, then WHO FROM ST. PAUL is responsible for adjusting those claims? The fact that NO ONE from St. Paul Travelers has not responded to those claims is another act of bad faith on the part of St. Paul, as well as your insureds.

You continue your letter by saying that “since all of your claims are barred, both by settlement and by court order, there is really nothing to discuss further with you.” Mr. Louie, what settlement, and what court order, are you talking about? There has been NO SETTLEMENT of these fraud, racketeering and bad faith claims. There is NO COURT ORDER barring me from making these claims of fraud, racketeering and bad faith against Jeffrey Sia, Sidney Ayabe and their law firm. These are false statements and further acts of bad faith on the part of the St. Paul Travelers.

Mr. Louie, since you advise that you will not be responding further to any of my claim letters, I consider this statement yet another act of bad faith on the part of the St. Paul Travelers. It is also, I suspect, an example of the type of irresponsible claims service that clients of the St. Paul Travelers may expect whenever they have a claim made against them. Since you will not be responding to me further, and since you have not provided me with the name and address of anyone who will be handling my fraud, racketeering and bad faith claims against Jeffrey Sia, Sidney Ayabe and their law firm, then I have no choice but to address my future claims letters directly to them, with the expectation that THEY will report these claims to the St. Paul Travelers, and that a licensed claims adjuster from St. Paul will be contacting me in a timely manner in compliance with Hawaii State Statutes.

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)