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White Tab 115 — Insurance Promise and Abandonment Sequence (Facts-Only)

GUARDRAIL: WHITE — FACT REPOSITORY ONLY

Facts & source pinpoints only. No strategy, no argument, no legal opinions. All quotations are "as reported" unless exact text appears in a cited source.

0) Role of This Tab (Facts-Only)

This tab is an affidavit-ready, facts-only sequence documenting the insurance promise → cooperation → abandonment pattern that emerges across the B.0–B.3 meeting framework and post-B.3 communications.

This tab is intended to support: - A001 ("The Story") Section 3.2 insurance-sequence clarification - WT-001 Master Timeline additions (late-2019 through post-B.3) - Purple Track 1 (Insurance Fraud) — "Fraud OF Gray" inducement theory (Purple is where legal theory belongs)

1) Sequence Summary (Facts-Only)

Core sequence (facts-only): 1. Insurance promise made (coverage representations to Gray).
2. Gray cooperates through meetings and documentation under the expectation of insurance-funded remediation.
3. At or by B.3, Gray learns the property claim paid out (as reported).
4. Gray seeks application of funds to remediation/losses; owner refuses (as reported).
5. Communications and follow-through cease (as reported).

2) Chronology (Facts-Only)

2.1 Insurance Promise (Late Nov 2019)

  • [Testimonial — Gray] Kofman represents that insurance would fund: (1) full remediation of G21, (2) rebuild to Gray's design specifications, and (3) compensation for flood-damaged professional and personal items. (Date approximate: Late Nov 2019.)

Corroboration context (documentary): - [Fact] On 2019-12-03, Gray's email to counsel memorializes insurance representations attributed to Kofman ("damages would be covered by his insurance") and references an "insurance money" framing. (WT-102)

2.2 Cooperation / Documentation (Late 2019 → Feb 2020)

  • [Documentary — Gray copies preserved] Gray preserves Methods & Materials documentation relating to studio rooms (exact file set: TBD; intake target for WT-003 packet).
  • [Fact] B.0–B.2 meetings occur (late Nov 2019 through mid/late Dec 2019) as documented in WT-104. (WT-104)

2.3 B.3 Meeting Sequence (2020-02-26) — Hallway + Kitchen (As Reported)

B.3 date: 2020-02-26 (WT-104).

Ordered sequence (facts-only; as reported): 1. [As Reported / Testimonial — Gray] Rivera discloses that the property claim was approved/paid out (language varies by account; treat as reported) in the hallway.
2. [As Reported / Testimonial — Gray] Katz reprimands Rivera for disclosing claim information to Gray.
3. [As Reported / Testimonial — Gray] Katz states: "we took your numbers and padded them."
4. [As Reported / Testimonial — Gray] Katz promises a "fat check" soon.

Documentary anchor: - [Fact] WT-104 B.3 is the controlling meeting framework source; witness profiles WT-201 (Katz) and WT-202 (Rivera) provide supporting context. (WT-104; WT-201; WT-202)

2.4 Post-B.3 Request (After 2020-02-26)

  • [Testimonial — Gray] Gray asks Kofman to apply insurance funds to the promised remediation / losses. (Date approximate: post-B.3.)

2.5 Refusal ("Sue me for it") (After 2020-02-26)

  • [Testimonial — Gray] Kofman refuses and states: "sue me for it." Per Gray's account, this refusal includes declining to apply proceeds to fund the promised remediation, rebuild-to-spec, or item compensation. (Date approximate: post-B.3.)

2.6 Stonewall / Process Cut-Off (After Refusal)

  • [Testimonial — Gray] Kofman stops taking Gray's calls.
  • [Testimonial — Gray] A promised personal-items list submission does not occur (as reported).

Potential corroboration targets (not yet pinned): - call logs, emails/texts, calendar notes (custodian: Gray) — TBD - any written request for the personal-items list and any response — TBD

3) Source Map (Facts-Only)

Primary sources: - WT-102 — Email to counsel (2019-12-03) (insurance representations; non-disclosure instruction context) - WT-103 — Great American declination letters (CGL declination; property carrier reference) - WT-104 — Pre-Insurance Inspection Meeting framework (B.0–B.3; meeting sequencing) - WT-201 — Evan Katz witness profile - WT-202 — Julian Rivera witness profile

Related: - WT-001 — Master Timeline (facts-only; chronology integration) - WT-003 — Discovery packets (future intake targets for Methods & Materials and corroboration items)

END — White Tab 115 — Insurance Promise and Abandonment Sequence (Facts-Only) v1.1