USS Panel

To whom it may concern: I was not aware that the Dominican Republic was a third world country in any case, [redacted] must have other issues for complaining about something that has been manufactured but not delivered yet until we are sure that she pays the amount due for her custom cut panels [redacted] knew perfectly well that our panels are not manufactured in the USA but in our offshore facilities, she was also told that our intentions and goal is to manufacture in the United States as we have been pursuing this since (we have a letter from the City of San Antonio attesting this)Our panels are fully tested and carry all the necessary USA codes and requirements, for sustainable building materials from the manufacturersShe never discussed the change order confirmed by qualified engineers, she just requested her money back on a piece of paper dropped off by her Designer [redacted] who we paid her trip to Las Vegas (since we had nothing to hide) as we were guests in the machine manufacturer booth [redacted] who charged a commission and was payed by USS-PANEL backed by a signed contract of NDNC and Non-Compete, on [redacted] invoices as she payed her due amounts as contracted, to USS-PANELShe totally violated her contract and referred to [redacted] who knows what We are a retailer with our own price listUsually a client before buying take their time and does a full due diligence and comparisons, and not half way thru a production and day away from delivery We did not oblige [redacted] to buy our product, and the USA manufacturer she is referring to and now want to use, do not make the panels she ordered us and we sold her, to make sure she had a complete monolithic envelope and cannot guarantee the same results, nor the assistance we have subscribed toThe damages she has a ported to our company are being quantified by our lawyer (who has tried to mediate but she has not responded see attached) as everything she has ordered is custom sized and cut for her small house of sqftand according to her gibberish, slander and bullying campaign we have to refund her because she has changed her mind without caring about or discussing the damages she is causing our companyShe and her designer have been harassing me personally we have filed a police report as some text was scary, and the other partners with text,email and as per attached copies of her public campaign, slander and racist insinuations toward our Engineer, without ever talking to us, our salesman or [redacted] and discussing face to face her problems and how to remedy the sameWe are ready to deliver her manufactured panels that are accumulating demurrage charges, once she deposits the rest of the amounts due including taxes As per her original contracted order, to an escrow agent or with our lawyerThis will assure her that the product being delivered are the right and qualified product made to order as per contract and her designed original plansThank you for your understanding, [redacted] ***, VP & COO -Unlimited Structural Solutions, Llcd/b/a USS-PANEL

To whom it may concern:I was not aware that the Dominican Republic was a third world country in any case, [redacted] must have other issues for complaining about something that has been manufactured but not delivered yet until we are sure that she pays the amount due for her custom cut panels [redacted] knew perfectly well that our panels are not manufactured in the USA but in our offshore facilities, she was also told that our intentions and goal is to manufacture in the United States as we have been pursuing this since (we have a letter from the City of San Antonio attesting this)Our panels are fully tested and carry all the necessary USA codes and requirements, for sustainable building materials from the manufacturersShe never discussed the change order confirmed by qualified engineers, she just requested her money back on a piece of paper dropped off by her Designer [redacted] who we paid her trip to Las Vegas (since we had nothing to hide) as we were guests in the machine manufacturer booth [redacted] who charged a commission and was payed by USS-PANEL backed by a signed contract of NDNC and Non-Compete, on [redacted] invoices as she payed her due amounts as contracted, to USS-PANELShe totally violated her contract and referred to [redacted] who knows what We are a retailer with our own price listUsually a client before buying take their time and does a full due diligence and comparisons, and not half way thru a production and day away from delivery We did not oblige [redacted] to buy our product, and the USA manufacturer she is referring to and now want to use, do not make the panels she ordered us and we sold her, to make sure she had a complete monolithic envelope and cannot guarantee the same results, nor the assistance we have subscribed toThe damages she has a ported to our company are being quantified by our lawyer (who has tried to mediate but she has not responded see attached) as everything she has ordered is custom sized and cut for her small house of sqftand according to her gibberish, slander and bullying campaign we have to refund her because she has changed her mind without caring about or discussing the damages she is causing our companyShe and her designer have been harassing me personally we have filed a police report as some text was scary, and the other partners with text,email and as per attached copies of her public campaign, slander and racist insinuations toward our Engineer, without ever talking to us, our salesman or [redacted] and discussing face to face her problems and how to remedy the sameWe are ready to deliver her manufactured panels that are accumulating demurrage charges, once she deposits the rest of the amounts due including taxes As per her original contracted order, to an escrow agent or with our lawyerThis will assure her that the product being delivered are the right and qualified product made to order as per contract and her designed original plansThank you for your understanding, [redacted] ***, VP & COO -Unlimited Structural Solutions, Llcd/b/a USS-PANEL

As per attached responsePlease review our previous responsesWe have provided all necessary documents that clearly refute Ms [redacted] claims and accusations with regard to Unlimited Structural Solution LLcAll other comments on her part are irrelevant to the resolution of this claimWe refuse to respond to any further fabrications and her attempts to extort and bully, the company and its members

As per attached response.Please review our previous responsesWe have provided all necessary documents that clearly refute Ms*** *** claims and accusations with regard to Unlimited Structural Solution LLc.All other comments on her part are irrelevant to the resolution of this claimWe refuse to respond to any further fabrications and her attempts to extort and bully, the company and its members

CONFIDENTIAL COMMUNICATION April 15, RE: Respondent’s, Unlimited Structural Solutions, LLC d/b/a USS-Panel’s, Timely Supplemental Response to the supplemental complaint presented in ID ***, dated April 6, TO THE Revdex.com Ladies and Gentlemen: We incorporate our previous Response to the allegations filed by our customer, the contractual buyer, the “Owner,” *** *** ** *** USS-Panel specifically and vigorously denies any and all allegations made by *** *** before the Revdex.com and/or before / with any other person, entity or agency, concerning any alleged “deceptive trade (and/or business) practices and/or all other groundless allegationsUSS-Panel asserts strongly that *** *** breached a written contract with USS-Panel, and immediately embarked on a concerted campaign to wrongly disparage and harass USS-Panel and its representative Ms*** ***, not only before the Revdex.com but in other forums and with other persons / entities / agenciesUSS-Panel supplied a bid for panels to the (prospective, at that time) buyer / Owner *** *** from a take-off of plans delivered to USS-Panel on December 30, 2015; USS-Panel made *** *** aware immediately that the elevations of the chimneys shown in the plans were not according to code, and *** *** indicated she would deliver an amended plan to USS-PanelThe buyer / Owner *** *** entered into and signed written contract with the Respondent, USS-Panel, on or about January 12, 2016, which is attached to this Response as Exhibit 1. *** *** was brought to USS-Panel by Ms*** ** ***, identified more particularly below. *** *** paid the required, agreed contractual installment payments to USS-Panel, necessary to provide to the manufacturer for commencing the prompt contractual manufacturing of the panels / product for *** ***, on January 12, 2016, and on February 1, 2016, totaling the sum of $67,714.96. This sum was used by USS-Panel entirely to pay to the manufacturer of the panels ordered by *** ***, and a commission to USS-Panel’s internal sales person (five percent of such sum) and to Ms*** ** ***, who is further identified below (five percent of such sum). USS-Panel did not make one penny from these installment payments. *** *** insisted on receiving five percent of the two installment payments described above, along with an all-expenses-paid trip to Las Vegas, which USS-Panel paid and paid forThe plans for *** ***’ panels / home were provided to USS-Panel by *** *** of Next Productions. *** *** brought the buyer / Owner, *** ***, to USS-Panel. *** *** signed a confidential Referral Agent Agreement with USS-Panel. The plans were amended by the Owner’s agents and engineer in the design of the foundation and structural plans for the product to be manufactured for USS-Panel for providing to *** *** under the contract, requiring an additional 1,square feet of roof / floor panel. These plans were delivered to the Respondent by Ms*** ** *** of Next Productions*** ***’ Complaint entirely ignores that *** *** signed a written contract with USS-Panel (more particularly described below and attached to this Response) containing a paragraph calling for “Change Orders” related to “any changes in the schedule of work, design, or of the specifications,” with written authorization by the Owner. A necessary change order was submitted to *** *** by USS-Panel after its receipt of revised plans from the Owner’s representatives, i.e., *** ***’ designer and her engineer. Within an hour, *** *** immediately repudiated the contract, refused to execute the necessary change order, demanded a full refund of her installment payments required for manufacturing her product on an agreed schedule, and embarked on a concerted, wrongful campaign, individually and along with *** ***, continuing to this date, in harassing and disparaging USS-Panel and Ms*** *** in numerous ways, including but not limited to (a) immediately and subsequently repeatedly, and wrongfully, demanding USS-Panel’s return of *** ***’ full contractual installment payments in the amount of $67,(apparently including *** ***’s paid commission, for which a full credit and/or offset was never offered), (b) filing this groundless complaint, (c) making disparaging postings on a Canadian website, www.TheSqueakyWheel.com (see Exhibit 2), (d) contacting state politicians / office holders, including but not limited to the office of a Texas state senator and the office of the Attorney General of Texas, (e) contacting at least one other (unrelated) customer of USS-Panel, (f) repeatedly emailing and texting USS-Panel and its attorney with her wrongful demands, including *** ***’ unfounded demands for a “refund” of her agreed contractual installment payments, (g) threatening lawsuit(s), and (h) threatening to file a complaint with the Federal Trade CommissionAs provided in the parties’ written contract, USS-Panel is a “Material Supplier” and “is strictly a retailer of expanded polystyrene insulated structural pre(-)form for walls, floors, and accessories and (is) not involved in contracting (--) we only sell these materials to contractors or to final users.” *** *** was not obliged to purchase products from USS-Panel until she signed the contract described more particularly belowThe “demand letter” received by *** *** from USS-Panel’s attorney dated March 9, 2016, attached as Exhibit 3, did not contain an “offer” from USS-Panel to *** *** because *** *** breached her written contract with USS-Panel by repudiating the contract immediately upon her receipt of a contractual change order made necessary by changes to the plans delivered to USS-Panel by *** *** and *** ***’ engineer. See Exhibit Any reference by *** *** to the Dominican Republic in this matter as being an alleged “deceptive trade practice” is also entirely misplaced insofar as (a) at a meeting in January USS-Panel explained to *** *** in the presence of others that there was a recent price increase in the panels but the earlier lower pricing could be maintained as a courtesy to *** ***, and that (b) the manufacturing facility for the panels was located in the Dominican Republic. Moreover, the parties’ written contract clearly states that *** ***’ failure to perform her own due diligence to ensure her own level of personal comfort / satisfaction in no way diminishes the terms of the contract she signed. Any references by *** *** in this matter to Ms*** *** allegedly “owning manufacturing facilities” is entirely misplaced insofar as the written contract in question is with USS-Panel and not *** *** individually, and *** *** does not own or have any interest in any panels-manufacturing facilities anywhereAny references by *** *** to *** *** cannot be addressed in this forum insofar as a signed non-disclosure agreement is active. Any references in this complaint to any prospective, threatened lawsuits to be filed by *** *** additionally would breach the parties’ written contract insofar as the agreed contract contains an Arbitration clause regarding all “claims, disputes, and other matters in question arising out of, or relating to, the Contract Documents or the breach thereof” before the American Arbitration Association in accordance with its Construction Industry Arbitration Rules In sum, *** ***’ complaint before the Revdex.com is in all things groundless and brought in bad faith or for purposes of harassmentAccordingly, USS-Panel respectfully requests that this Complaint in all things be denied and dismissed at the soonest possible timeThank you for your courtesies, consideration and assistance with regard to this matter. Please feel free to call if you have any questionsRespectfully submitted, USS-PANEL By: /s/ *** *** *** *** Corporate VP & COO direct line: +*** UNLIMITED STRUCTURAL SOLUTIONS, LLC1T +* *** *** *** *** ***
*** *** *** *** T+*** *** *** F* *** *** www.uss-panel.com

Complaint: [redacted]
I am rejecting this response because:
[redacted]’ Response to [redacted]’s Response to My Complaint to Revdex.com Of course, my choice is to reject this response since there isn’t an offer included in it at all. I apologize that my response is so lengthy but I feel that it is vital that I present evidence to support my claim. The letter she attached from her lawyer is a demand-for-payment letter--nowhere within it is the word “mediation.” I will respond POINT-by-POINT. Following these POINTs and ATTACHMENTS/EXHIBITS, there will be a final ATTACHMENT/EXHIBIT, which is a TIMELINE (ATTACHMENT/EXHIBIT 10). (POINT 1) In all fairness to the Dominican Republic (DR), the term “third world” ended with the cold war. It has been replaced by demographers calling the DR a “developing country.” So let me restate: The Dominican Republic is NOT fully developed; and I, nor anyone I know, would purchase 100% of my structural house from a developing country/the Dominican Republic. That’s a big enough issue. (POINT 2) However, I absolutely have many other issues besides [redacted]’s LIES and deceptive business practices and marketing materials that state the panels are manufactured in the U.S.A., and which I partially addressed in my complaint to the Revdex.com. Please read on… (POINT 3) The panels are NOT “custom cut” to fit my house: They are standard sizes, to use [redacted]’s own words “prefabricated three-dimensional lightweight structural panels,” which she should have calculated and ordered in the correct amounts; she didn’t. In addition, she ordered only 3 standard thicknesses of panels for load-bearing interior and exterior walls, floors, roof, ceilings, and non-loadbearing interior walls. However, 5 different thicknesses of panels are required per my blueprints/plans! She also ordered 5 different kinds (3 U-meshes, 1 angular, and 1 flat) of mesh (when we only needed 4 kinds of mesh) in the wrong amounts for internal and external reinforcement for every window, every door, every corner, to connect the panels to the floors, and the panels to the roof joists. Two of these 5 types of mesh (596 pieces) are completely unusable because they do not fit any of the panels she ordered! We needed 1550 pieces of the 4 kinds of mesh that would fit the panels. For example, she miscalculated that 426 pieces of 3 kinds of U-meshes would be needed when we actually need 600 of the correct kinds of U-meshes. 110 of the pieces she ordered would not fit the 3.94” panels she ordered because the U-mesh she ordered is only 3.54” wide, being 0.40” too small! Also, we are 164 four-footpieces short of a critical structural angular mesh for corners that [redacted] ordered, because she ordered 486 pieces instead of the 650 pieces required. All of this has been corroborated in writing by 2 SCIP panel-and-mesh experts. Therefore, the construction of my home with what she ordered would have had to come to a complete halt because the mesh is an integral part of the Structural Concrete Insulated Panel (SCIP) system—I would have had to wait another 8 weeks for the correct mesh to arrive from the Dominican Republic! This would cost an enormous amount of interest and penalties on my construction loan for these 2 extra months, and 2 additional months beyond my lease agreement of expensive month-to-month rental for my current apartment. This doesn’t even include the extra time it would take to get the electrical, plumbing, and propane subcontractors back out to the house to complete their work. NOTE: This is not gibberish, nor is it slander. These are cold, hard verified facts of her incompetence. (POINT 4) In her response to my complaint to the Revdex.com, [redacted] wrote that I “knew perfectly well that our panels are not manufactured in the USA but in our offshore facilities.” This is an outright LIE. I did NOT know that these panels are not manufactured in the USA; [redacted] told me they were manufactured in the U.S.A. and never told me otherwise! To prove that, I am attaching two of the marketing materials (ATTACHMENTS/EXHIBITS 1 and 2) that she provided me and which clearly states USS-Panel “a Texas based company manufactures and distributes this…building 2 system.” BUT, she does NOT own any U.S. and/or “offshore facilities” that manufacture panels! Nor did she ever tell me she intends to eventually build her own factory in the U.S., and she certainly never showed me a letter from the City of San Antonio attesting that she eventually wants to manufacture panels in the U.S.; and I find it hard to believe that such a letter even exists. Also see her post on Thumbtack (ATTACHMENT/EXHIBIT 3) in which she writes, “We manufacture, sell and built sustainable disaster proof homes…” [redacted] also asserts in ATTACHMENT/EXHIBIT 4 that “We are constantly updating our product manufacturing machines…,” another LIE because she owns no manufacturing facilities. The POINT is she does NOT manufacture panels in the U.S. now, and LIED to me that she does. This is not gibberish, nor is it slander. These are cold, hard facts of her deceptive “bait and switch” business practices. (POINT 5) It wasn’t until my designer [redacted]’s return from the Las Vegas Concrete Trade Show and my return from visiting family on the West Coast on 2/21/16 that I was told the panels are not manufactured in the U.S. I was very upset that I had been LIED to by [redacted]. She then sent me an email on 2/25/16 with a new request (44 days after our agreement was signed!) for yet more money, $12,763.76, and LIED again, this time blaming my architect for a design change requiring 1100 more square feet of panels. One of the engineers she refers to in her response as having “confirmed” the change order, and who was introduced to me as her “in-house” foundation/framing/civil engineer [redacted] (who really has his own business, Trinity Group, and offices in New Braunfels, not located in the USSPanel office in San Antonio), and who I later retained to design the foundation, actually REFUTED, NOT confirmed, her claim, writing that no additional panels for the roof design would be needed; so she LIED in her response there as well. My POINT in mentioning that her other “in-house” (structural?, we think) engineer [redacted] is from Haiti is NOT about his race (I never met him so I wouldn’t know his race, so THAT’s the real slander: [redacted] stating in writing that I am a racist!)—it’s about the fact that he lives and works there and is NOT LICENSED in the United States of America, nor in the State of Texas, and everything he would do would have to be signed off by a licensed-in-the-U.S.A. engineer! For example, [redacted] could not legally sign off on the Technical Evaluation Report (TER) that is required by the mortgage company and building permit since he is not licensed in Texas. [redacted]’s collaborating with [redacted], in fact, would be impossible since [redacted] made sure that David, the licensed foundation/framing/civil engineer, has no contact information for [redacted], the structural(?) engineer, to enable them to consult with one another on how my home should be structurally and soundly built. Silvan [redacted] LIES and incompetence over and over again, were the last straw. I want all of my money back. I cannot believe nor trust ANYTHING that [redacted] has said to me. This POINT is crystal clear, not “gibberish” nor “slander” nor racism, but more examples of her deceptive business practices. (POINT 6) In her response, [redacted] states that “Our panels are fully tested and carry all the necessary USA codes and requirements, for sustainable building materials from the manufacturers.” Because she had told me her company, USS-Panel, is the manufacturer of the panels, it was important to investigate this claim. The US Green Building Council (whose logo is on the invoice component of our agreement of 1/12/16) said they never heard of [redacted] or USS-Panel or Unlimited Structural Solutions, and their legal department would like to discuss this further. However, now that I know she LIED and does not manufacture the panels in the U.S., that they instead are manufactured in the Dominican Republic, the question becomes, does she own the factory in the Dominican Republic because in her response she is calling the panels HERS [sic. “Our panels”] and calling the factory HERS [sic. “our offshore facilities”]? She does not; she owns no factories anywhere! This means she is consistently telling LIES, confirming her intent to defraud. To this day, I do not know the name of the factory in the Dominican Republic nor in her response has she offered any proof that the panels manufactured there have of all the certifications whose logos are on her invoices and marketing 3 materials. I have attached the full list of certifications (ATTACHMENT/EXHIBIT 5) from her marketing materials that she claimed the panels “manufactured” by USS-Panel have--Of course, she includes the logo of the US Green Building Council but forgot to include them in the list. This is not gibberish, nor slander, but more evidence of her LIES, deceptive business practices, “bait and switch” techniques, incompetence, and intent to defraud. Moreover, the U.S. Federal Trade Commission (FTC) per ftc.gov “is charged with preventing deception and unfairness in the marketplace. The FTC Act gives the Commission the power to bring law enforcement actions against false or misleading claims that a product is of U.S. origin.” The FTC also states that “the Lanham Act gives any person…who is damaged by a false designation of origin the right to sue the party making the false claim.” I will not sue for all the damages (such as the costs of being 2 months behind on building my dream home, month-to-month apartment rent, storage of my possessions, mental anguish, etc.) if [redacted] immediately and fully refunds my $67,714.96. If [redacted]/USS-Panel/Unlimited Structural Solutions, LLC/Universal Safety Solutions Corporation does not immediately refund my $67,714.96, which I would gladly accept from her lawyer, I will have no choice but to pursue all legal remedies available to me. (POINT 7) In her response, [redacted] claims to be a “retailer with our own price list.” I believe that this is another LIE for a couple of reasons. First, she never showed me a price list. This leads me to believe that the only price list she has is the one the factory gave her so she knows HER costs when she buys panels from them. Second, her latest demand on Feb. 25, 2016 with a new invoice totaling $12,763.76 for the additional 1100 square feet of panels and mesh that she forgot to include/ miscalculated the first time was at an increased rate per unit of panels than the original invoice on which I had already paid $67,714.96. [redacted] stated in this demand that there would be additional charges unless I didn’t make her 2-workday deadline for payment. So, she LIED again and had already raised the price anyway! Additionally, [redacted] told me on Jan. 5th that she would order 10% more panels than she calculated so there’d be more than enough for the house, a shed, an enclosure for the propane tank, and a rainwater collection system. Ultimately, [redacted] decided to order, without discussing it with me what she determined would be 6% extra panels. Obviously, all of her calculations were completely wrong. (POINT 8) During our first meeting on Jan. 5, 2016, [redacted] impressed upon [redacted] and me the fact that USS-Panel is the only company in Texas that manufactures and distributes SCIP panels. [redacted] showed us several videos of SCIP system construction, gave us technical information and many marketing materials, and claimed to have built many structures familiar to us, such as a Whole Foods store in Austin. When [redacted] asked to meet with the owners or see some of the structures, [redacted] said she could not because [redacted] had non-disclosure agreements with the owners. [redacted] also stated that the SCIP system costs 20% less than a conventional woodframe home (see ATTACHMENTS/EXHIBITs 6, 7 and 8), and that there was an impending price increase of over $10,000, and knew that I wanted my home built by June when my lease expires. [redacted] knew I did not yet have a mortgage since it required my having a contract with a builder and a home appraisal value. However, I had been pre-approved by 2 lenders and we gave [redacted] those details. [redacted] even LIED that Unlimited Structural Solutions, LLC, had built the house in [redacted]hat withstood Tornado Ike (see ATTACHMENT 4. It was a hurricane, not a tornado, and Unlimited Structural Solutions, LLC, did NOT build the house; it also occurred in 2008 before [redacted]’s business was set up in Texas—but we did not know this at the time.). We fully believed in the SCIP system and [redacted]’s scam tactics and LIES and feel we did what due diligence was available to us. Had the Dominican Republic been mentioned at any time as the location of the manufacturing factory instead of a USS-Panel location in the U.S., we would have walked 4 out the door and never purchased anything. She LIED. When [redacted] did not offer to discuss or meet with me after I let her know that I could not afford the additional money she claimed she needed on Feb. 25th, we launched an investigation on Mar. 9th into our other options for SCIP panels made in the U.S.A., and found the factory in Mississippi that charges considerably less than [redacted]. Note: This was not an arbitrary cost comparison “20 days before delivery” as [redacted] states in her response. In her response to my Revdex.com complaint, [redacted] implied that the Mississippi manufacturer of SCIP panels does not have a complete monolithic envelope system. During our investigations, [redacted] and I discovered that they are actually certified and accredited, and DO have a complete monolithic envelope system, as verified by the Structural Building Components Research Institute (SBCRI). The Mississippi manufacturers have prior experience with [redacted] who purchased panels from them in the past. Their experience with her has not been positive. In her response to my Revdex.com complaint, [redacted] states that if we use the Mississippi manufacturers she “cannot guarantee the same results nor the assistance we have subscribed to.” To date the results of working with [redacted] are horrifically poor: incompetent panel and mesh count and type selection, incompetent estimation practices, price gouging, and refusing to refund my $67,714.96. In fact, the final result of working with [redacted] would be my having NO home because it is unbuildable with the panels and mesh she ordered; not to mention the fact that with $125,622.02 of panels and mesh, without including structural mortar, rebar, and labor costs, no one can build my home for the mortgage amount for which I qualify because of her price gouging; and finally, [redacted] clearly does not care because she ordered the panels anyway knowing I do not qualify for a mortgage to pay her hugely inflated costs for them. (POINT 9) As I thoroughly discussed in POINT 3 above, none of the panels are custom-sized and cut, per [redacted]’s own literature (ATTACHMENT/EXHIBIT 9) calling them “prefabricated”, which is the exact opposite of custom-cut/-sized. Also, I am fully within my legal rights to lodge a complaint with the Revdex.com and every legitimate avenue I have at my disposal to help me get my full refund of $67,714.96, and to inform other consumers about this nightmare scam so they can make educated decisions about using USS-Panel. To date, I have not received a certified letter from her attorney, only the attachment [redacted] uploaded in her response to the Revdex.com. I see that in the attachment her attorney never mentioned the word “mediation”—This makes her response that her lawyer “has tried to mediate” yet another LIE. Since the panels and mesh are “prefabricated,” and their production was halted before completion when [redacted] received my repudiation on Feb. 26th requesting a full refund, and the panels and mesh have not been shipped, there should be no demurrage charges. In addition, since [redacted] did not order the panels/mesh until Wed., February 10th , there were only 12 working days between the 10th and the 25th. [redacted]’s original invoice in the agreement states that it would take up to 8 weeks to be delivered, so most likely very few (not 95% as she told her lawyer) panels/mesh were completed in those 12 working days. As detailed above in POINT 3, especially since the panels/mesh are completely unusable to build my house, I cannot afford to waste $45,143.31 due upon delivery for a product that is unknown, unusable, and not made in the U.S.A. as promised. Regarding [redacted]’s/USS-Panel’s supposed loss of business because I have exercised my legal rights to lodge a complaint with the Revdex.com and use every legitimate avenue I have at my disposal to help me get my full refund of $67,714.96, and to inform other consumers about this nightmare scam so they can make educated decisions about using USS-Panel, any loss of business would be based on her intent to defraud me of $125,622.02, and not based on any malicious intent by me or [redacted]. (POINT 10) Based on [redacted]’s unsubstantiated claim in her response that [redacted] and I had harassed her and that she filed a police report, [redacted] and I went to the Police Substation to investigate. 5 The San Antonio Police Department’s (SAPD) [redacted] (badge #[redacted]) told [redacted] when she came to the Substation that [redacted]’s text message to [redacted] “does not meet the criteria for a threat or harassment report” and that he would not write it up as such. I have personally read the text messages [redacted] sent to [redacted] asking for my full refund, and agree with Officer Krick. In addition, in her response [redacted] LIED saying that I had harassed her. In her response [redacted] also claimed that I made no effort to discuss these problems, that is a LIE. Acting as my own lawyer, I sent emails requesting my full refund of $67,714.96 to her and her business partners, and even gave her an extension. She only responded that I should talk to her lawyer. She never made any attempt to discuss this face-to-face nor suggest any remedies. When I contacted her salesman, he responded only that I should communicate with her. When I repeatedly contacted her partner, and her CEO/husband, I received no response at all from either of them. You cannot have a discussion when no one communicates with you! This refutes [redacted]’s claim in her response that I made no attempt to discuss the situation with them. A legal definition of “slander” is making a false spoken statement damaging to a person's reputation; and a legal definition of “libel” is making a false written statement damaging to a person's reputation. [redacted] and I have done neither. I have evidence substantiating all of my claims of [redacted]’s deceptive trade and marketing practices, such as false advertising that the panels are manufactured in the U.S.A., all of which violate U.S. Federal Trade Commission requirements. Therefore, my irrefutable evidence is not slander. Moreover, [redacted]’s charge of bullying does not apply. Bullying is unwanted, aggressive behavior among school aged children that involves a real or perceived power imbalance. The behavior is repeated, or has the potential to be repeated, over time. The only victim here is me: I cannot move forward on building my dream retirement home until my $67,714.96 is refunded. In addition, Duhaime.org’s legal dictionary defines “Consumer scam” as “a deceptive sale of goods or services to a consumer designed to extract money unreasonably excessive given the services rendered or goods provided, if any.” There is no doubt that [redacted]’s charging me almost 2.5 times the going rate for panels and mesh is “unreasonably excessive” and that I am the victim of [redacted]’s/USS-Panel’s/Unlimited Structural Solutions, LLC’s/Universal Safety Solutions Corporation’s scam!! I have all the evidence to prove it. (POINT 11) In her response, she refers to my “small” house as 3966 square feet; another miscalculation by [redacted] of 1,274 square feet. On my blueprints/plans, which [redacted] has had since she had them printed on 12/29/15, it clearly states that my 2-story home has 2692 square feet of living area. (POINT 12) [redacted]’s last couple of sentences of her response to my complaint to the Revdex.com include a comment that if I pay the remaining amount for the “product,” it will “assure” me that the product being delivered “are the right and qualified product made to order as per contract and her designed original plans.” This is yet another LIE: The product(s) are NOT “right” (i.e., NOT correct/usable numbers and types of panels and mesh), also NOT made to order but prefabricated, and also will NOT fit my blueprints/plans which my architect has NOT changed by 1100 square feet! [redacted] ignored the fact that I could not build my home with her panels with the mortgage for which I was qualified. She left for the “unknown” factory on Feb. 9th to order and pay for my SCIP panels/mesh anyway, knowing 100% from HER general contractor/builder that my home could NOT be built because of the excessive costs of the panels and mesh. Instead, she should have considerably reduced the cost of the panels and mesh because she was already charging me more than double, or not ordered them at 6 all. This shows [redacted]’s unethical business practices and greed, as well as her intent to get as much money from me as she could, caring nothing about the fact that my house could not be built. I’d have a homesite lot with panels and mesh just sitting there, and no mortgage. The 2 deposits ($67,714.96 total) that I paid to [redacted] for the panels and mesh came from my retirement savings, not from a mortgage. Other Issues There are many additional serious questions and issues of concern regarding [redacted]’s business practices, such as: Were my panels and mesh insured by [redacted]/USS-Panel or the factory in the Dominican Republic or the cargo ship or the trucking company that would deliver my entire house of walls, floors, ceilings, and roof? If there was one, who would be the beneficiary? Had any of this been shown to me, I would have known that 100% of my structural home would be coming from a developing country, the Dominican Republic; and we would not be spending my time with this complaint--I’d be building my small dream house of 2692 square feet with a reputable company in the U.S.A. with U.S.A.- manufactured panels and mesh! The final ATTACHMENT/EXHIBIT of this response package is a TIMELINE OF EVENTS (ATTACHMENT/EXHIBIT 10). SUMMARY This preponderance of evidence in POINTS 1 through 12, ATTACHMENTS/EXHIBITS, including the TIMELINE (see ATTACHMENT/EXHIBIT 10), clearly prove with absolutely NO doubt that [redacted] of USS-Panel did in fact show WILLFUL INTENT to DEFRAUD me. I will not sue for all the damages (such as the costs of being 2 months behind on building my dream home, month-to-month apartment rent, storage of my possessions, mental anguish, etc.) if [redacted] immediately and fully refunds my $67,714.96. If [redacted]/USS-Panel/Unlimited Structural Solutions, LLC/Universal Safety Solutions Corporation does not immediately refund my $67,714.96, which I would gladly accept from her lawyer, I will have no choice but to pursue all legal remedies available to me. About Us I have been an educator for more than 35 years, have presented testimony to the U.S. Congress, held education sessions on aging for Congress and their legislative aides, chaired Advisory Committees to STATE AGENCIES, co-convened a NATIONAL COALITION OF MAJOR ORGANIZATIONS, served on many BOARDS OF PROFESSIONAL ORGANIZATIONS, and served as PRESIDENT of two INTERNATIONAL PROFESSIONAL ORGANIZATIONS. I am a Fellow or a Diplomate of six PROFESSIONAL ORGANIZATIONS. I am a trusted health professional and service volunteer. In short, I do not lie. [redacted] has over 35 years of design and construction experience, having worked for numerous national builders and VIP clients during her career. I personally have hired her to work with me on various projects for almost 5 years. She is of the highest integrity, completely honest, and I have always trusted in her expertise. She always has had a key to each of my residences during these 5 years. Solution Statement On Jan. 12, 2016, [redacted] stated that she “would buy back any unused panels.” Per [redacted]’s own admission on Feb. 25, 2016 (see ATTACHMENT/EXHIBIT 10-TIMELINE), a), there are not enough panels (at a minimum 1100 square feet of them) to build my house. [redacted] grossly neglected to 7 estimate the second floor ceiling, not due to a plan change by my architect as she claims. The 1100 square feet of panels that are missing just happen to be within 12 feet of the square footage of the second floor in the blueprints/plans. Also, she ordered the wrong types and amounts of panels and mesh. Therefore, we cannot use any of them. I know [redacted] is currently working with another client, [redacted] Garza, who will be using factory prefabricated SCIP panels to build his 3 investment properties located on Hackberry and Dawson streets in San Antonio, TX. So, the solution is that since SCIP panels come in prefabricated standard sizes, and not custom-cut at the factory, and since the panels [redacted] ordered for my home will NOT be usable for my home according to the 2 panel/mesh experts and by her own admission, it would be beneficial for [redacted] to sell the panels for my home to [redacted] and purchase the rest of the panels he needs, in order to refund my $67,714.96 in full. Respectfully submitted, [redacted] FACD, FICD, FASGD, FGSA, DABSCD, FAGHE
Regards,
[redacted]

To whom it may concern:
I was not aware that the Dominican Republic was a third world country in any case, [redacted] must have other issues for complaining about something that has been manufactured but not delivered yet until we are sure that she pays the amount due for her custom cut...

panels. [redacted] knew perfectly well that our panels are not manufactured in the USA but in our offshore facilities, she was also told that our intentions and goal is to manufacture in the United States as we have been pursuing this since 2010 (we have a letter from the City of San Antonio attesting this). Our panels are fully tested and carry all the necessary USA codes and requirements, for sustainable building materials from the manufacturers. She never discussed the change order confirmed by 2 qualified engineers, she just requested her money back on a piece of paper dropped off by her Designer [redacted] who we paid her trip to Las Vegas (since we had nothing to hide) as we were guests in the machine manufacturer booth. [redacted] who charged a commission and was payed by USS-PANEL backed by a signed contract of NDNC and Non-Compete, on [redacted] invoices as she payed her due amounts as contracted, to USS-PANEL. She totally violated her contract and referred to [redacted] who knows what.  We are a retailer with our own price list. Usually a client before buying take their time and does a full due diligence and comparisons, and not half way thru a production and 20 day away from delivery.  We did not oblige [redacted] to buy our product, and the USA manufacturer she is referring to and now want to use,  do not make the panels she ordered us and we sold her, to make sure she had a complete monolithic envelope and cannot guarantee the same results, nor the assistance we have subscribed to. The damages she has a ported to our company are being quantified by our lawyer (who has tried to mediate but she has not responded see attached) as everything she has ordered is custom sized and cut for her small house of 3966 sq. ft. and according to her gibberish, slander and bullying campaign we have to refund her because she has changed her mind without caring about or discussing the damages she is causing our company. She and her designer have been harassing me personally we have filed a police report as some text was scary, and the other partners with text,email and as per attached copies of her public campaign, slander and racist insinuations toward our Engineer, without ever talking to us, our salesman or [redacted] and discussing face to face her problems and how to remedy the same. We are ready to deliver her manufactured  panels that are accumulating demurrage charges, once she deposits the rest of the amounts due including taxes As per her original contracted order, to an escrow agent or with our lawyer. This will assure her that the product  being delivered are the right and qualified product made to order as per contract and her designed original plans. Thank you for your understanding, [redacted], VP & COO -Unlimited Structural Solutions, Llc. d/b/a USS-PANEL

As per attached response.
Please review our previous responses. We have provided all necessary documents that clearly refute Ms. [redacted] claims and accusations with regard to Unlimited Structural Solution LLc.
All other comments on her part are irrelevant to the resolution of this claim. We refuse to respond to any further fabrications and her attempts to extort and bully, the company and its members.

To whom it may concern:I was not aware that the Dominican Republic was a third world country in any case, [redacted] must have other issues for complaining about something that has been manufactured but not delivered yet until we are sure that she pays the amount due for her custom cut...

panels. [redacted] knew perfectly well that our panels are not manufactured in the USA but in our offshore facilities, she was also told that our intentions and goal is to manufacture in the United States as we have been pursuing this since 2010 (we have a letter from the City of San Antonio attesting this). Our panels are fully tested and carry all the necessary USA codes and requirements, for sustainable building materials from the manufacturers. She never discussed the change order confirmed by 2 qualified engineers, she just requested her money back on a piece of paper dropped off by her Designer [redacted] who we paid her trip to Las Vegas (since we had nothing to hide) as we were guests in the machine manufacturer booth. [redacted] who charged a commission and was payed by USS-PANEL backed by a signed contract of NDNC and Non-Compete, on [redacted] invoices as she payed her due amounts as contracted, to USS-PANEL. She totally violated her contract and referred to [redacted] who knows what.  We are a retailer with our own price list. Usually a client before buying take their time and does a full due diligence and comparisons, and not half way thru a production and 20 day away from delivery.  We did not oblige [redacted] to buy our product, and the USA manufacturer she is referring to and now want to use,  do not make the panels she ordered us and we sold her, to make sure she had a complete monolithic envelope and cannot guarantee the same results, nor the assistance we have subscribed to. The damages she has a ported to our company are being quantified by our lawyer (who has tried to mediate but she has not responded see attached) as everything she has ordered is custom sized and cut for her small house of 3966 sq. ft. and according to her gibberish, slander and bullying campaign we have to refund her because she has changed her mind without caring about or discussing the damages she is causing our company. She and her designer have been harassing me personally we have filed a police report as some text was scary, and the other partners with text,email and as per attached copies of her public campaign, slander and racist insinuations toward our Engineer, without ever talking to us, our salesman or [redacted] and discussing face to face her problems and how to remedy the same. We are ready to deliver her manufactured  panels that are accumulating demurrage charges, once she deposits the rest of the amounts due including taxes As per her original contracted order, to an escrow agent or with our lawyer. This will assure her that the product  being delivered are the right and qualified product made to order as per contract and her designed original plans. Thank you for your understanding, [redacted], VP & COO -Unlimited Structural Solutions, Llc. d/b/a USS-PANEL

Complaint: [redacted]
I am rejecting this response because:[redacted]’ Response to [redacted]’s Response to My Complaint to Revdex.com Of course, my choice is to reject this response since there isn’t an offer included in it at all. I apologize that my response is so lengthy but I feel that it is vital that I present evidence to support my claim. The letter she attached from her lawyer is a demand-for-payment letter--nowhere within it is the word “mediation.” I will respond POINT-by-POINT. Following these POINTs and ATTACHMENTS/EXHIBITS, there will be a final ATTACHMENT/EXHIBIT, which is a TIMELINE (ATTACHMENT/EXHIBIT 10). (POINT 1) In all fairness to the Dominican Republic (DR), the term “third world” ended with the cold war. It has been replaced by demographers calling the DR a “developing country.” So let me restate: The Dominican Republic is NOT fully developed; and I, nor anyone I know, would purchase 100% of my structural house from a developing country/the Dominican Republic. That’s a big enough issue. (POINT 2) However, I absolutely have many other issues besides [redacted]’s LIES and deceptive business practices and marketing materials that state the panels are manufactured in the U.S.A., and which I partially addressed in my complaint to the Revdex.com. Please read on… (POINT 3) The panels are NOT “custom cut” to fit my house: They are standard sizes, to use [redacted]’s own words “prefabricated three-dimensional lightweight structural panels,” which she should have calculated and ordered in the correct amounts; she didn’t. In addition, she ordered only 3 standard thicknesses of panels for load-bearing interior and exterior walls, floors, roof, ceilings, and non-loadbearing interior walls. However, 5 different thicknesses of panels are required per my blueprints/plans! She also ordered 5 different kinds (3 U-meshes, 1 angular, and 1 flat) of mesh (when we only needed 4 kinds of mesh) in the wrong amounts for internal and external reinforcement for every window, every door, every corner, to connect the panels to the floors, and the panels to the roof joists. Two of these 5 types of mesh (596 pieces) are completely unusable because they do not fit any of the panels she ordered! We needed 1550 pieces of the 4 kinds of mesh that would fit the panels. For example, she miscalculated that 426 pieces of 3 kinds of U-meshes would be needed when we actually need 600 of the correct kinds of U-meshes. 110 of the pieces she ordered would not fit the 3.94” panels she ordered because the U-mesh she ordered is only 3.54” wide, being 0.40” too small! Also, we are 164 four-footpieces short of a critical structural angular mesh for corners that [redacted] ordered, because she ordered 486 pieces instead of the 650 pieces required. All of this has been corroborated in writing by 2 SCIP panel-and-mesh experts. Therefore, the construction of my home with what she ordered would have had to come to a complete halt because the mesh is an integral part of the Structural Concrete Insulated Panel (SCIP) system—I would have had to wait another 8 weeks for the correct mesh to arrive from the Dominican Republic! This would cost an enormous amount of interest and penalties on my construction loan for these 2 extra months, and 2 additional months beyond my lease agreement of expensive month-to-month rental for my current apartment. This doesn’t even include the extra time it would take to get the electrical, plumbing, and propane subcontractors back out to the house to complete their work. NOTE: This is not gibberish, nor is it slander. These are cold, hard verified facts of her incompetence. (POINT 4) In her response to my complaint to the Revdex.com, [redacted] wrote that I “knew perfectly well that our panels are not manufactured in the USA but in our offshore facilities.” This is an outright LIE. I did NOT know that these panels are not manufactured in the USA; [redacted] told me they were manufactured in the U.S.A. and never told me otherwise! To prove that, I am attaching two of the marketing materials (ATTACHMENTS/EXHIBITS 1 and 2) that she provided me and which clearly states USS-Panel “a Texas based company manufactures and distributes this…building 2 system.” BUT, she does NOT own any U.S. and/or “offshore facilities” that manufacture panels! Nor did she ever tell me she intends to eventually build her own factory in the U.S., and she certainly never showed me a letter from the City of San Antonio attesting that she eventually wants to manufacture panels in the U.S.; and I find it hard to believe that such a letter even exists. Also see her post on Thumbtack (ATTACHMENT/EXHIBIT 3) in which she writes, “We manufacture, sell and built sustainable disaster proof homes…” [redacted] also asserts in ATTACHMENT/EXHIBIT 4 that “We are constantly updating our product manufacturing machines…,” another LIE because she owns no manufacturing facilities. The POINT is she does NOT manufacture panels in the U.S. now, and LIED to me that she does. This is not gibberish, nor is it slander. These are cold, hard facts of her deceptive “bait and switch” business practices. (POINT 5) It wasn’t until my designer [redacted]’s return from the Las Vegas Concrete Trade Show and my return from visiting family on the West Coast on 2/21/16 that I was told the panels are not manufactured in the U.S. I was very upset that I had been LIED to by [redacted]. She then sent me an email on 2/25/16 with a new request (44 days after our agreement was signed!) for yet more money, $12,763.76, and LIED again, this time blaming my architect for a design change requiring 1100 more square feet of panels. One of the engineers she refers to in her response as having “confirmed” the change order, and who was introduced to me as her “in-house” foundation/framing/civil engineer [redacted] (who really has his own business, Trinity Group, and offices in New Braunfels, not located in the USSPanel office in San Antonio), and who I later retained to design the foundation, actually REFUTED, NOT confirmed, her claim, writing that no additional panels for the roof design would be needed; so she LIED in her response there as well. My POINT in mentioning that her other “in-house” (structural?, we think) engineer [redacted] is from Haiti is NOT about his race (I never met him so I wouldn’t know his race, so THAT’s the real slander: [redacted] stating in writing that I am a racist!)—it’s about the fact that he lives and works there and is NOT LICENSED in the United States of America, nor in the State of Texas, and everything he would do would have to be signed off by a licensed-in-the-U.S.A. engineer! For example, [redacted] could not legally sign off on the Technical Evaluation Report (TER) that is required by the mortgage company and building permit since he is not licensed in Texas. [redacted]’s collaborating with [redacted], in fact, would be impossible since [redacted] made sure that David, the licensed foundation/framing/civil engineer, has no contact information for [redacted], the structural(?) engineer, to enable them to consult with one another on how my home should be structurally and soundly built. Silvan [redacted] LIES and incompetence over and over again, were the last straw. I want all of my money back. I cannot believe nor trust ANYTHING that [redacted] has said to me. This POINT is crystal clear, not “gibberish” nor “slander” nor racism, but more examples of her deceptive business practices. (POINT 6) In her response, [redacted] states that “Our panels are fully tested and carry all the necessary USA codes and requirements, for sustainable building materials from the manufacturers.” Because she had told me her company, USS-Panel, is the manufacturer of the panels, it was important to investigate this claim. The US Green Building Council (whose logo is on the invoice component of our agreement of 1/12/16) said they never heard of [redacted] or USS-Panel or Unlimited Structural Solutions, and their legal department would like to discuss this further. However, now that I know she LIED and does not manufacture the panels in the U.S., that they instead are manufactured in the Dominican Republic, the question becomes, does she own the factory in the Dominican Republic because in her response she is calling the panels HERS [sic. “Our panels”] and calling the factory HERS [sic. “our offshore facilities”]? She does not; she owns no factories anywhere! This means she is consistently telling LIES, confirming her intent to defraud. To this day, I do not know the name of the factory in the Dominican Republic nor in her response has she offered any proof that the panels manufactured there have of all the certifications whose logos are on her invoices and marketing 3 materials. I have attached the full list of certifications (ATTACHMENT/EXHIBIT 5) from her marketing materials that she claimed the panels “manufactured” by USS-Panel have--Of course, she includes the logo of the US Green Building Council but forgot to include them in the list. This is not gibberish, nor slander, but more evidence of her LIES, deceptive business practices, “bait and switch” techniques, incompetence, and intent to defraud. Moreover, the U.S. Federal Trade Commission (FTC) per ftc.gov “is charged with preventing deception and unfairness in the marketplace. The FTC Act gives the Commission the power to bring law enforcement actions against false or misleading claims that a product is of U.S. origin.” The FTC also states that “the Lanham Act gives any person…who is damaged by a false designation of origin the right to sue the party making the false claim.” I will not sue for all the damages (such as the costs of being 2 months behind on building my dream home, month-to-month apartment rent, storage of my possessions, mental anguish, etc.) if [redacted] immediately and fully refunds my $67,714.96. If [redacted]/USS-Panel/Unlimited Structural Solutions, LLC/Universal Safety Solutions Corporation does not immediately refund my $67,714.96, which I would gladly accept from her lawyer, I will have no choice but to pursue all legal remedies available to me. (POINT 7) In her response, [redacted] claims to be a “retailer with our own price list.” I believe that this is another LIE for a couple of reasons. First, she never showed me a price list. This leads me to believe that the only price list she has is the one the factory gave her so she knows HER costs when she buys panels from them. Second, her latest demand on Feb. 25, 2016 with a new invoice totaling $12,763.76 for the additional 1100 square feet of panels and mesh that she forgot to include/ miscalculated the first time was at an increased rate per unit of panels than the original invoice on which I had already paid $67,714.96. [redacted] stated in this demand that there would be additional charges unless I didn’t make her 2-workday deadline for payment. So, she LIED again and had already raised the price anyway! Additionally, [redacted] told me on Jan. 5th that she would order 10% more panels than she calculated so there’d be more than enough for the house, a shed, an enclosure for the propane tank, and a rainwater collection system. Ultimately, [redacted] decided to order, without discussing it with me what she determined would be 6% extra panels. Obviously, all of her calculations were completely wrong. (POINT 8) During our first meeting on Jan. 5, 2016, [redacted] impressed upon [redacted] and me the fact that USS-Panel is the only company in Texas that manufactures and distributes SCIP panels. [redacted] showed us several videos of SCIP system construction, gave us technical information and many marketing materials, and claimed to have built many structures familiar to us, such as a Whole Foods store in Austin. When [redacted] asked to meet with the owners or see some of the structures, [redacted] said she could not because [redacted] had non-disclosure agreements with the owners. [redacted] also stated that the SCIP system costs 20% less than a conventional woodframe home (see ATTACHMENTS/EXHIBITs 6, 7 and 8), and that there was an impending price increase of over $10,000, and knew that I wanted my home built by June when my lease expires. [redacted] knew I did not yet have a mortgage since it required my having a contract with a builder and a home appraisal value. However, I had been pre-approved by 2 lenders and we gave [redacted] those details. [redacted] even LIED that Unlimited Structural Solutions, LLC, had built the house in [redacted]hat withstood Tornado Ike (see ATTACHMENT 4. It was a hurricane, not a tornado, and Unlimited Structural Solutions, LLC, did NOT build the house; it also occurred in 2008 before [redacted]’s business was set up in Texas—but we did not know this at the time.). We fully believed in the SCIP system and [redacted]’s scam tactics and LIES and feel we did what due diligence was available to us. Had the Dominican Republic been mentioned at any time as the location of the manufacturing factory instead of a USS-Panel location in the U.S., we would have walked 4 out the door and never purchased anything. She LIED. When [redacted] did not offer to discuss or meet with me after I let her know that I could not afford the additional money she claimed she needed on Feb. 25th, we launched an investigation on Mar. 9th into our other options for SCIP panels made in the U.S.A., and found the factory in Mississippi that charges considerably less than [redacted]. Note: This was not an arbitrary cost comparison “20 days before delivery” as [redacted] states in her response. In her response to my Revdex.com complaint, [redacted] implied that the Mississippi manufacturer of SCIP panels does not have a complete monolithic envelope system. During our investigations, [redacted] and I discovered that they are actually certified and accredited, and DO have a complete monolithic envelope system, as verified by the Structural Building Components Research Institute (SBCRI). The Mississippi manufacturers have prior experience with [redacted] who purchased panels from them in the past. Their experience with her has not been positive. In her response to my Revdex.com complaint, [redacted] states that if we use the Mississippi manufacturers she “cannot guarantee the same results nor the assistance we have subscribed to.” To date the results of working with [redacted] are horrifically poor: incompetent panel and mesh count and type selection, incompetent estimation practices, price gouging, and refusing to refund my $67,714.96. In fact, the final result of working with [redacted] would be my having NO home because it is unbuildable with the panels and mesh she ordered; not to mention the fact that with $125,622.02 of panels and mesh, without including structural mortar, rebar, and labor costs, no one can build my home for the mortgage amount for which I qualify because of her price gouging; and finally, [redacted] clearly does not care because she ordered the panels anyway knowing I do not qualify for a mortgage to pay her hugely inflated costs for them. (POINT 9) As I thoroughly discussed in POINT 3 above, none of the panels are custom-sized and cut, per [redacted]’s own literature (ATTACHMENT/EXHIBIT 9) calling them “prefabricated”, which is the exact opposite of custom-cut/-sized. Also, I am fully within my legal rights to lodge a complaint with the Revdex.com and every legitimate avenue I have at my disposal to help me get my full refund of $67,714.96, and to inform other consumers about this nightmare scam so they can make educated decisions about using USS-Panel. To date, I have not received a certified letter from her attorney, only the attachment [redacted] uploaded in her response to the Revdex.com. I see that in the attachment her attorney never mentioned the word “mediation”—This makes her response that her lawyer “has tried to mediate” yet another LIE. Since the panels and mesh are “prefabricated,” and their production was halted before completion when [redacted] received my repudiation on Feb. 26th requesting a full refund, and the panels and mesh have not been shipped, there should be no demurrage charges. In addition, since [redacted] did not order the panels/mesh until Wed., February 10th , there were only 12 working days between the 10th and the 25th. [redacted]’s original invoice in the agreement states that it would take up to 8 weeks to be delivered, so most likely very few (not 95% as she told her lawyer) panels/mesh were completed in those 12 working days. As detailed above in POINT 3, especially since the panels/mesh are completely unusable to build my house, I cannot afford to waste $45,143.31 due upon delivery for a product that is unknown, unusable, and not made in the U.S.A. as promised. Regarding [redacted]’s/USS-Panel’s supposed loss of business because I have exercised my legal rights to lodge a complaint with the Revdex.com and use every legitimate avenue I have at my disposal to help me get my full refund of $67,714.96, and to inform other consumers about this nightmare scam so they can make educated decisions about using USS-Panel, any loss of business would be based on her intent to defraud me of $125,622.02, and not based on any malicious intent by me or [redacted]. (POINT 10) Based on [redacted]’s unsubstantiated claim in her response that [redacted] and I had harassed her and that she filed a police report, [redacted] and I went to the Police Substation to investigate. 5 The San Antonio Police Department’s (SAPD) [redacted] (badge #[redacted]) told [redacted] when she came to the Substation that [redacted]’s text message to [redacted] “does not meet the criteria for a threat or harassment report” and that he would not write it up as such. I have personally read the text messages [redacted] sent to [redacted] asking for my full refund, and agree with Officer Krick. In addition, in her response [redacted] LIED saying that I had harassed her. In her response [redacted] also claimed that I made no effort to discuss these problems, that is a LIE. Acting as my own lawyer, I sent emails requesting my full refund of $67,714.96 to her and her business partners, and even gave her an extension. She only responded that I should talk to her lawyer. She never made any attempt to discuss this face-to-face nor suggest any remedies. When I contacted her salesman, he responded only that I should communicate with her. When I repeatedly contacted her partner, and her CEO/husband, I received no response at all from either of them. You cannot have a discussion when no one communicates with you! This refutes [redacted]’s claim in her response that I made no attempt to discuss the situation with them. A legal definition of “slander” is making a false spoken statement damaging to a person's reputation; and a legal definition of “libel” is making a false written statement damaging to a person's reputation. [redacted] and I have done neither. I have evidence substantiating all of my claims of [redacted]’s deceptive trade and marketing practices, such as false advertising that the panels are manufactured in the U.S.A., all of which violate U.S. Federal Trade Commission requirements. Therefore, my irrefutable evidence is not slander. Moreover, [redacted]’s charge of bullying does not apply. Bullying is unwanted, aggressive behavior among school aged children that involves a real or perceived power imbalance. The behavior is repeated, or has the potential to be repeated, over time. The only victim here is me: I cannot move forward on building my dream retirement home until my $67,714.96 is refunded. In addition, Duhaime.org’s legal dictionary defines “Consumer scam” as “a deceptive sale of goods or services to a consumer designed to extract money unreasonably excessive given the services rendered or goods provided, if any.” There is no doubt that [redacted]’s charging me almost 2.5 times the going rate for panels and mesh is “unreasonably excessive” and that I am the victim of [redacted]’s/USS-Panel’s/Unlimited Structural Solutions, LLC’s/Universal Safety Solutions Corporation’s scam!! I have all the evidence to prove it. (POINT 11) In her response, she refers to my “small” house as 3966 square feet; another miscalculation by [redacted] of 1,274 square feet. On my blueprints/plans, which [redacted] has had since she had them printed on 12/29/15, it clearly states that my 2-story home has 2692 square feet of living area. (POINT 12) [redacted]’s last couple of sentences of her response to my complaint to the Revdex.com include a comment that if I pay the remaining amount for the “product,” it will “assure” me that the product being delivered “are the right and qualified product made to order as per contract and her designed original plans.” This is yet another LIE: The product(s) are NOT “right” (i.e., NOT correct/usable numbers and types of panels and mesh), also NOT made to order but prefabricated, and also will NOT fit my blueprints/plans which my architect has NOT changed by 1100 square feet! [redacted] ignored the fact that I could not build my home with her panels with the mortgage for which I was qualified. She left for the “unknown” factory on Feb. 9th to order and pay for my SCIP panels/mesh anyway, knowing 100% from HER general contractor/builder that my home could NOT be built because of the excessive costs of the panels and mesh. Instead, she should have considerably reduced the cost of the panels and mesh because she was already charging me more than double, or not ordered them at 6 all. This shows [redacted]’s unethical business practices and greed, as well as her intent to get as much money from me as she could, caring nothing about the fact that my house could not be built. I’d have a homesite lot with panels and mesh just sitting there, and no mortgage. The 2 deposits ($67,714.96 total) that I paid to [redacted] for the panels and mesh came from my retirement savings, not from a mortgage. Other Issues There are many additional serious questions and issues of concern regarding [redacted]’s business practices, such as: Were my panels and mesh insured by [redacted]/USS-Panel or the factory in the Dominican Republic or the cargo ship or the trucking company that would deliver my entire house of walls, floors, ceilings, and roof? If there was one, who would be the beneficiary? Had any of this been shown to me, I would have known that 100% of my structural home would be coming from a developing country, the Dominican Republic; and we would not be spending my time with this complaint--I’d be building my small dream house of 2692 square feet with a reputable company in the U.S.A. with U.S.A.- manufactured panels and mesh! The final ATTACHMENT/EXHIBIT of this response package is a TIMELINE OF EVENTS (ATTACHMENT/EXHIBIT 10). SUMMARY This preponderance of evidence in POINTS 1 through 12, ATTACHMENTS/EXHIBITS, including the TIMELINE (see ATTACHMENT/EXHIBIT 10), clearly prove with absolutely NO doubt that [redacted] of USS-Panel did in fact show WILLFUL INTENT to DEFRAUD me. I will not sue for all the damages (such as the costs of being 2 months behind on building my dream home, month-to-month apartment rent, storage of my possessions, mental anguish, etc.) if [redacted] immediately and fully refunds my $67,714.96. If [redacted]/USS-Panel/Unlimited Structural Solutions, LLC/Universal Safety Solutions Corporation does not immediately refund my $67,714.96, which I would gladly accept from her lawyer, I will have no choice but to pursue all legal remedies available to me. About Us I have been an educator for more than 35 years, have presented testimony to the U.S. Congress, held education sessions on aging for Congress and their legislative aides, chaired Advisory Committees to STATE AGENCIES, co-convened a NATIONAL COALITION OF MAJOR ORGANIZATIONS, served on many BOARDS OF PROFESSIONAL ORGANIZATIONS, and served as PRESIDENT of two INTERNATIONAL PROFESSIONAL ORGANIZATIONS. I am a Fellow or a Diplomate of six PROFESSIONAL ORGANIZATIONS. I am a trusted health professional and service volunteer. In short, I do not lie. [redacted] has over 35 years of design and construction experience, having worked for numerous national builders and VIP clients during her career. I personally have hired her to work with me on various projects for almost 5 years. She is of the highest integrity, completely honest, and I have always trusted in her expertise. She always has had a key to each of my residences during these 5 years. Solution Statement On Jan. 12, 2016, [redacted] stated that she “would buy back any unused panels.” Per [redacted]’s own admission on Feb. 25, 2016 (see ATTACHMENT/EXHIBIT 10-TIMELINE), a), there are not enough panels (at a minimum 1100 square feet of them) to build my house. [redacted] grossly neglected to 7 estimate the second floor ceiling, not due to a plan change by my architect as she claims. The 1100 square feet of panels that are missing just happen to be within 12 feet of the square footage of the second floor in the blueprints/plans. Also, she ordered the wrong types and amounts of panels and mesh. Therefore, we cannot use any of them. I know [redacted] is currently working with another client, [redacted] Garza, who will be using factory prefabricated SCIP panels to build his 3 investment properties located on Hackberry and Dawson streets in San Antonio, TX. So, the solution is that since SCIP panels come in prefabricated standard sizes, and not custom-cut at the factory, and since the panels [redacted] ordered for my home will NOT be usable for my home according to the 2 panel/mesh experts and by her own admission, it would be beneficial for [redacted] to sell the panels for my home to [redacted] and purchase the rest of the panels he needs, in order to refund my $67,714.96 in full. Respectfully submitted, [redacted] FACD, FICD, FASGD, FGSA, DABSCD, FAGHE
Regards,
[redacted]

CONFIDENTIAL COMMUNICATION April 15, 2016 RE:   Respondent’s, Unlimited Structural Solutions, LLC d/b/a USS-Panel’s, Timely Supplemental Response to the supplemental complaint presented in ID [redacted], dated April 6, 2016. TO THE Revdex.com Ladies and Gentlemen: We incorporate our previous Response to the allegations filed by our customer, the contractual buyer, the “Owner,” [redacted]  USS-Panel specifically and vigorously denies any and all allegations made by [redacted] before the Revdex.com and/or before / with any other person, entity or agency, concerning any alleged “deceptive trade (and/or business) practices and/or all other groundless allegations. USS-Panel asserts strongly that [redacted] breached a written contract with USS-Panel, and immediately embarked on a concerted campaign to wrongly disparage and harass USS-Panel and its representative Ms. [redacted], not only before the Revdex.com but in other forums and with other persons / entities / agencies. USS-Panel supplied a bid for panels to the (prospective, at that time) buyer / Owner [redacted] from a take-off of plans delivered to USS-Panel on December 30, 2015; USS-Panel made [redacted] aware immediately that the elevations of the chimneys shown in the plans were not according to code, and [redacted] indicated she would deliver an amended plan to USS-Panel. The buyer / Owner [redacted] entered into and signed written contract with the Respondent, USS-Panel, on or about January 12, 2016, which is attached to this Response as Exhibit 1.  [redacted] was brought to USS-Panel by Ms. [redacted], identified more particularly below.  [redacted] paid the required, agreed contractual installment payments to USS-Panel, necessary to provide to the manufacturer for commencing the prompt contractual manufacturing of the panels / product for [redacted], on January 12, 2016, and on February 1, 2016, totaling the sum of $67,714.96.  This sum was used by USS-Panel entirely to pay to the manufacturer of the panels ordered by [redacted], and a commission to USS-Panel’s internal sales person (five percent of such sum) and to Ms. [redacted], who is further identified below (five percent of such sum).  USS-Panel did not make one penny from these installment payments.  [redacted] insisted on receiving five percent of the two installment payments described above, along with an all-expenses-paid trip to Las Vegas, which USS-Panel paid and paid for. The plans for [redacted]’ panels / home were provided to USS-Panel by [redacted] of Next Productions.  [redacted] brought the buyer / Owner, [redacted], to USS-Panel.  [redacted] signed a confidential Referral Agent Agreement with USS-Panel.  The plans were amended by the Owner’s agents and engineer in the design of the foundation and structural plans for the product to be manufactured for USS-Panel for providing to [redacted] under the contract, requiring an additional 1,100 square feet of roof / floor panel.  These plans were delivered to the Respondent by Ms. [redacted] of Next Productions. [redacted]’ Complaint entirely ignores that [redacted] signed a written contract with USS-Panel (more particularly described below and attached to this Response) containing a paragraph calling for “Change Orders” related to “any changes in the schedule of work, design, or of the specifications,” with written authorization by the Owner.  A necessary change order was submitted to [redacted] by USS-Panel after its receipt of revised plans from  the Owner’s representatives, i.e., [redacted]’ designer and her engineer.  Within an hour, [redacted] immediately repudiated the contract, refused to execute the necessary change order, demanded a full refund of her installment payments required for manufacturing her product on an agreed schedule, and embarked on a concerted, wrongful campaign, individually and along with [redacted], continuing to this date, in harassing and disparaging USS-Panel and Ms. [redacted] in numerous ways, including but not limited to (a) immediately and subsequently repeatedly, and wrongfully, demanding USS-Panel’s return of [redacted]’ full contractual installment payments in the amount of $67,714.96. (apparently including [redacted]’s paid commission, for which a full credit and/or offset was never offered), (b) filing this groundless complaint, (c) making disparaging postings on a Canadian website, www.TheSqueakyWheel.com (see Exhibit 2),  (d) contacting state politicians / office holders, including but not limited to the office of a Texas state senator and the office of the Attorney General of Texas, (e) contacting at least one other (unrelated) customer of USS-Panel, (f) repeatedly emailing and texting USS-Panel and its attorney with her wrongful demands, including [redacted]’ unfounded demands for a “refund” of her agreed contractual installment payments, (g) threatening lawsuit(s), and (h) threatening to file a complaint with the Federal Trade Commission. As provided in the parties’ written contract, USS-Panel is a “Material Supplier” and “is strictly a retailer of expanded polystyrene insulated structural pre(-)form for walls, floors, and accessories and (is) not involved in contracting (--) we only sell these materials to contractors or to final users.”  [redacted] was not obliged to purchase products from USS-Panel until she signed the contract described more particularly below. The “demand letter” received by [redacted] from USS-Panel’s attorney dated March 9, 2016, attached as Exhibit 3, did not contain an “offer” from USS-Panel to [redacted] because [redacted] breached her written contract with USS-Panel by repudiating the contract immediately upon her receipt of a contractual change order made necessary by changes to the plans delivered to USS-Panel by [redacted] and [redacted]’ engineer.  See Exhibit 4. Any reference by [redacted] to the Dominican Republic in this matter as being an alleged “deceptive trade practice” is also entirely misplaced insofar as (a) at a meeting in January 2016 USS-Panel explained to [redacted] in the presence of others that there was a recent price increase in the panels but the earlier lower pricing could be maintained as a courtesy to [redacted], and that (b) the manufacturing facility for the panels was located in the Dominican Republic.  Moreover, the parties’ written contract clearly states that [redacted]’ failure to perform her own due diligence to ensure her own level of personal comfort / satisfaction in no way diminishes the terms of the contract she signed.  Any references by [redacted] in this matter to Ms. [redacted] allegedly “owning manufacturing facilities” is entirely misplaced insofar as the written contract in question is with USS-Panel and not [redacted] individually, and [redacted] does not own or have any interest in any panels-manufacturing facilities anywhere. Any references by [redacted] to [redacted] cannot be addressed in this forum insofar as a signed non-disclosure agreement is active.  Any references in this complaint to any prospective, threatened lawsuits to be filed by [redacted] additionally would breach the parties’ written contract insofar as the agreed contract contains an Arbitration clause regarding all “claims, disputes, and other matters in question arising out of, or relating to, the Contract Documents or the breach thereof” before the American Arbitration Association in accordance with its Construction Industry Arbitration Rules.    In sum, [redacted]’ complaint before the Revdex.com is in all things groundless and brought in bad faith or for purposes of harassment. Accordingly, USS-Panel respectfully requests that this Complaint in all things be denied and dismissed at the soonest possible time. Thank you for your courtesies, consideration and assistance with regard to this matter.  Please feel free to call if you have any questions. Respectfully submitted,             USS-PANEL             By:  /s/ [redacted] Corporate VP & COOdirect line: +[redacted]UNLIMITED STRUCTURAL SOLUTIONS, LLC. 1
T +[redacted] T. +[redacted] F. [redacted]www.uss-panel.com

Complaint: [redacted]
I am rejecting this response because:
Dr. [redacted]. [redacted]’ April 25, 2016 Response to [redacted] Response of April 15, 2016 Again, as I did in my prior response of April 5, 2016, I will address [redacted] most recent response point-by-point. Each numbered point corresponds to each of the first 19 paragraphs in her response. 1.    First and foremost, [redacted], CEO of USS-Panel and Unlimited Structural Solutions LLC (a non-U.S. citizen here on a visa, and unlicensed in the State of Texas to do financial planning), who signed the agreement on January 12, 2016, and [redacted] (COO and Corporate Vice President of a woman-owned business) dba USS-Panel, Unlimited Structural Solutions LLC, Universal Safety Solutions Corporation, DESS-Holdings LLC, Services and Development Worldwide LLC, and Tyren Corporation (hereinafter “Defendants”), do business for all of the above at [redacted]which is a 4-room office in an industrial strip center that they claim to be their “headquarters” for “distribution centers across the country.” Their other businesses in Nevada included Rockefeller International Financial Group LLC (revoked by the State of Nevada, but still doing business in Barcelona, Spain, under [redacted] name—see Exhibit A), Enerfin Holding Company (revoked by the State of Nevada), PSI Holding Inc. (revoked by the State of Nevada), Financial Business Group LLC (revoked by the State of Nevada), Services & Development Worldwide LLC (revoked by the State of Nevada), Services and Development International LLC (revoked by the State of Nevada), and EHF Holdings LLC (revoked by the State of Nevada). Along with all of their Texas businesses the Nevada businesses will be hereinafter “The Defendants’ Companies”, whether conducting business or just adding to the investigation of “Their” business practices, all of which should be investigated including their association to DESS-Holdings, LLC, and its business(?) relationship to The Annunciation of the Most Holy Theotokos Romanian Patriarchate Monastery (located here just outside of San Antonio—See Exhibit B). Also in the interest of brevity, I will hereinafter refer to myself as either “I” or “The Plaintiff Dr. MS”. 2.    Second, in her most recent response on April 15, 2016, [redacted] accused The Plaintiff Dr. MS of making “groundless allegations.” However, on April 5, 2016, I submitted many pages of evidence to the contrary, so there is nothing that is “groundless”: These are not allegations, they are facts and evidence, not fiction! The response of [redacted] to these facts on April 15, 2016, merely consists of more of her lies. Repeating lies over and over and over does not make them true, especially in the face of evidence! 3.    Third, [redacted] wrongfully accused The Plaintiff Dr. MS of breaching a written contract, when in fact, the Defendants breached the contract with their deceptive trade practices and false advertising, including misrepresenting their products as having been manufactured by them in the U.S.! Further, [redacted] wrongfully accused The Plaintiff Dr. MS of immediately embarking on a “concerted campaign to wrongly disparage and harass USS-Panel and its representative Ms. [redacted], not only before the Revdex.com but in other forums and with other persons/entities/agencies.” On February 25, 2016, after the Defendants tried to extort another $12,763.76 in a two-day demand for a change order that THEY generated for panels and mesh that THEY neglected to accurately estimate both in number and type in the original agreement dated January 12, 2016, because they forgot the second floor, The Plaintiff Dr. MS then requested a full refund because the Defendants clearly have no experience and knowledge of the construction industry! Once the Defendants refused to give The Plaintiff Dr. MS a full refund, it certainly is The Plaintiff Dr. MS’s right as a U.S. citizen to exercise that right to report deceptive trade practices and fraud to the Revdex.com and all other forums, and appropriate agencies and entities, in an effort to pursue justice and seek a refund. 1
4.    Fourth, NO plans were delivered to the Defendants on December 30, 2015, as they claim. In fact, on December 29, 2015, the Defendants requested copies of The Plaintiff Dr. MS’s blueprints/plans from [redacted] Printworks ([redacted]), [redacted], and picked them up from [redacted]. [redacted] will be happy to verify this. This is fact and evidence, not fiction. The Defendants were told on or about December 22-23, 2015, by The Plaintiff Dr. MS’s designer [redacted] that these blueprints/plans were not “finals” since a plumbing line and propane line needed to be added, but the Defendants insisted they had to have a copy of the plans right then. NOTE: [redacted] told the Defendants that the addition of the plumbing and propane lines would go through the foundation and would NOT affect the footprint, square footage, elevations of the plans, and thus NOT affect the number or types of panels or mesh! This is FACT and EVIDENCE not FICTION. See The Plaintiff Dr. MS’s response items 10 and 11 below. In addition, [redacted] (NOT the Defendants!) was the one who brought up the issue of the chimney height to the Defendant’s engineer [redacted] when we met him on or about January 5, 2016. [redacted] suggested the chimneys be higher. However, he was wrong, since 4 Austin builders have since told The Plaintiff Dr. MS and [redacted] that the chimneys are within code at the shorter height being far enough away from the roofline per the December 29, 2015 plans. 5.    Fifth, [redacted], as CEO of USS-Panel, signed the agreement, not [redacted]. He is in the U.S. on a visa from Italy. He has been a CEO and officer of most of The Defendants’ Companies, 13 in all, most of which have been revoked by the State of Nevada (See Exhibit C.) 6.    Sixth, The Plaintiff Dr. MS did NOT pay the “installment payments to USS-Panel” as [redacted] claimed in her response. The checks were paid to “USS Corporation” which The Plaintiff Dr. MS assumes is the Defendants’ company Universal Safety Solutions Corporation (USS Corp.). This is confusing since USS Corp. is NOT the Defendants’ Company that holds the trademark “USS-Panel”. The Defendants’ Company that holds the trademark “USS-Panel” is Unlimited Structural Solutions LLC (USS LLC). 7.    Seventh, The Plaintiff Dr. MS does not believe that the “entirety” of the $67,714.96 that she paid to the Defendants was used to pay the manufacturer of the panels in the Dominican Republic and the commissions to The Plaintiff Dr. MS’s designer [redacted] and USS-Panel’s “internal sales person” as the Defendants claim via [redacted] most recent response. The Defendants need to provide the receipts of payment received by the manufacturer and [redacted], since The Plaintiff Dr. MS already has seen [redacted]. Since the Defendants price-gouged The Plaintiff Dr. MS for almost 2.5 times the cost of the panels and mesh, it is unlikely that the Defendants would willingly provide the receipt! [redacted], who stains concrete for a living, and was recently retained in November 2015 as “USS-Panel’s internal sales person”, actually did nothing to earn 5% commission, not one penny. On January 5, 2016, he promised to put together a proposal for a faux-standing-seam roof design for the concrete and Structural Concrete Insulated Panels (SCIP) for the roof. To this date, April 25, 2016, The Plaintiff Dr. MS has never received any such estimate as promised from [redacted]. When The Plaintiff Dr. MS contacted him, he referred her to the Defendants. 8.    and 9. Eighth and ninth, the claim by the Defendants that they have not made “one penny” from The Plaintiff Dr. MS’s payments to them is laughable at best! The Defendants had confessed to [redacted] that they were very low on funds. Therefore, the $67,714.96 that The Plaintiff Dr. MS paid to the Defendants served to finance the trip (for the Defendants, [redacted], [redacted]) to the Las Vegas Concrete Trade Show on February 2-6, 2016, as well as the Defendants’ upgrade from a 2-bedroom to a new 4-bedroom residence, two websites at $1500 each, and construction equipment the Defendants claimed to have bought at the Trade Show. 2
Since [redacted] insisted, in both her April 1, and April 15 responses, on accusing [redacted] J. [redacted] of various wrongdoings and unethical business practices, it is, therefore, only right that [redacted] J. [redacted] have the opportunity to speak for herself in this response. See her Notarized Affidavit in Exhibit D. 10. and 11. Tenth and eleventh, the amended blueprints/plans actually included 3 new items (1. A plumbing line through the foundation to the outdoor kitchen sink; 2. A propane line going to the range in the kitchen and the indoor fireplace, both requiring NO change in the floor plan, square footage, or roof elevation; and 3. An increase in chimney height which was NOT necessary, but [redacted] had asked [redacted], the Defendants’ engineer, and he suggested the chimneys be taller.) Four Austin home builders who reviewed the plans all agreed that Austin Building Code did not require any increase in chimney height. However, if, in fact, they had needed to be taller, this would have required exterior load-bearing vertical panels of at least 3.83” thick, not the 10.24” thick roof and floor panels that the Defendants insisted were needed. [redacted], introduced to us on or about January 5, 2016 as the Defendants’ engineer, refuted via email the Defendants’ claim that any additional roof panels would be needed. He further refuted the Defendants’ claim that 1100 square feet of panels would be needed, stating that it would take only leftover panel scraps, a “waste kind of thing” to make any roof adjustments should they be needed. This is FACT and EVIDENCE not fiction. The 1100 square feet of panels addressed in the change order of 10.24” thick roof and floor panels are approximately the second floor square footage of 1088 square feet! See Exhibits E and F, the former being December 2015’s original blueprints/plans, and the latter January 2016’s revised blueprints/plans. These plans clearly prove there was never at any time a change in the square footage or roof design. This is irrefutable fact and evidence, not fiction. This is PROOF that the Defendants are lying. Again, the Defendants are repeating lies over and over and hoping that will make them true. It won’t. [redacted] of Trinity Group was introduced to us on or about January 5, 2016, as well as in The Construction News article and photo, as the Defendants’ engineer (See Exhibit G.). The Defendants only started calling him my (The Plaintiff Dr. MS’s) engineer (as they do in Point 15 below) when he vehemently objected to lying that the change order would require 1100 additional square feet of floor and roof panels, costing $12,763.76. [redacted] will not risk his reputation and engineer’s license to further perpetuate the defendants’ fraud. Finally regarding Points 10 and 11, as well as Point 15 below, and most importantly, according to the signed agreement, “USS-Panel agrees not to make any changes in the schedule of work, design, or the specifications without written authorization by the owner. And the owner agrees not to make any design changes after the receipt of the materials.” NO MATERIALS WERE EVER RECEIVED. Even more damning is the fact that the December blueprints/plans without the plumbing and propane lines, nor the chimney height increase when compared to the January blueprints/plans showing the 3 changes, as well as the CAD file, were analyzed by [redacted] Printworks, McCullough and Associates (architect), and another registered architect and found to be IDENTICAL. NO SQUARE FOOTAGE CHANGES TO THE FOUNDATION AND STRUCTURAL PLANS WERE EVER MADE. Again, the revisions were only a plumbing line to the outdoor kitchen sink and propane lines to the kitchen range and living room fireplace. PERIOD. This is fact and evidence (proof!) that the Defendants lied, not mere allegations. 12. Twelfth, restating the above in Point 3: [redacted] wrongfully accused The Plaintiff Dr. MS of breaching a written contract, when in fact, the Defendants breached the contract with their deceptive trade practices and false advertising, including misrepresenting their products as having been manufactured by them in the U.S.! Further, [redacted] wrongfully accused The Plaintiff Dr. MS of 3
immediately embarking on a “concerted campaign to wrongly disparage and harass USS-Panel and its representative Ms. [redacted], not only before the Revdex.com but in other forums and with other persons/entities/agencies.” On February 25, 2016, after the Defendants tried to extort another $12,763.76 in a two-day demand for a change order that THEY generated for panels and mesh that THEY neglected to accurately estimate both in number and type in the original agreement dated January 12, 2016, because they forgot the second floor, The Plaintiff Dr. MS then requested a full refund because the Defendants clearly have no experience and knowledge of the construction industry! Once the Defendants refused to give The Plaintiff Dr. MS a full refund, it certainly is The Plaintiff Dr. MS’s right as a U.S. citizen to exercise that right to report deceptive trade practices and fraud to the Revdex.com and all other forums, and appropriate agencies and entities, in an effort to pursue justice and seek a refund. 13.   Thirteenth, the poster on the wall in the USS-Panel office states that the Defendants are “General Contractors” (see Exhibit G), and many of their deceptive marketing materials state that the Defendants “build” (See the deceptive trade marketing materials exhibits from The Plaintiff Dr. MS’s response of April 5, 2016 in which the materials repeatedly state that the Defendants “build” using the panels, most specifically their false claim that they built the house near Galveston that survived Hurricane Ike, which they called a tornado!) 14.   Fourteenth, The Plaintiff Dr MS was conned into purchasing products from the Defendants in their scam to defraud her. 15.   Fifteenth, restating the above in Points 10 and 11: According to the signed agreement, “USS-Panel agrees not to make any changes in the schedule of work, design, or the specifications without written authorization by the owner. And the owner agrees not to make any design changes after the receipt of the materials.” NO MATERIALS WERE EVER RECEIVED. Even more damning is the fact that the December blueprints/plans without the plumbing and propane lines, nor the chimney height increase when compared to the January blueprints/plans showing the 3 changes, as well as the CAD file, were analyzed by [redacted] Printworks, McCullough and Associates (architect), and another registered architect and found to be IDENTICAL. NO SQUARE FOOTAGE CHANGES TO THE FOUNDATION AND STRUCTURAL PLANS WERE EVER MADE. Again, the revisions were only a plumbing line to the outdoor kitchen sink and propane lines to the kitchen range and living room fireplace. PERIOD. This is fact and evidence (proof!) that the Defendants lied, not mere allegations. Also, again, [redacted] of Trinity Group was introduced to us on or about January 5, 2016, as well as in The Construction News article and photo, as the Defendants’ engineer (See Exhibit G.). The Defendants only started calling him my (The Plaintiff Dr. MS’s) engineer when he vehemently objected to lying that the change order would require 1100 additional square feet of floor and roof panels, costing $12,763.76. [redacted] will not risk his reputation and engineer’s license to further perpetuate the defendants’ fraud. 16.   Sixteenth, at no time, including the meeting on or about January 5, 2016, when others were present, did the Defendants ever say “their” panels were manufactured in the Dominican Republic! Again, [redacted] of Trinity Group was introduced to us at that meeting, as well as in The Construction News article and photo, as the Defendants’ engineer (See Exhibit G.). He is honest and has tremendous integrity, and will confirm that the Defendants NEVER told us during the meeting that their panels were manufactured in the Dominican Republic!!! [redacted] will not risk his reputation and engineer’s license to further perpetuate the defendants’ lies and fraud. In fact, the first time The Plaintiff Dr. MS
4
was informed by [redacted] that the panels were manufactured in the Dominican Republic was in her most recent response! 17.      Seventeenth, [redacted] states in her most recent response that any “references by Dr. [redacted] in this matter to Ms. [redacted] allegedly ‘owning manufacturing facilities’ is entirely misplaced insofar as the written contract in question is with USS-Panel and not Ms. [redacted] individually, and Ms. [redacted] does not own or have any interest in any panels-manufacturing facilities anywhere.” Regarding the first part of this response, in The Defendants’ deceptive trade practices, including marketing materials, website, and verbal statements, they repeatedly include that they “manufacture” the panels. The Plaintiff Dr. MS included several of the marketing materials in her last response. If the Defendants do not own any manufacturing facilities, it proves that the Defendants’ trade practices are indeed deceptive! (See the deceptive trade marketing materials exhibits from The Plaintiff Dr. MS’s response of April 5, 2016 in which the materials repeatedly state that the Defendants “manufacture and distribute” the panels!) 18.      Eighteenth, regarding Ms. [redacted] J. [redacted], The Plaintiff Dr. MS’s designer, it was [redacted] who repeatedly brought up Ms. [redacted] in both of her responses. Since she did so, it is certainly Ms. [redacted]’s right to respond. Therefore, Ms. [redacted] has submitted a notarized affidavit. See Exhibit D. 19.      Nineteenth, The Plaintiff Dr. MS’s complaint to the Revdex.com is in all things accurate and proven with FACTS AND EVIDENCE and brought in good faith NOT harassment. Once again, [redacted] thinks she can keep lying and eventually everyone will believe her. It doesn’t work that way. Truth, facts, and evidence CANNOT be “denied” nor “dismissed”! SUMMARY and SOLUTION STATEMENT The preponderance of evidence in The Plaintiff Dr. MS’s response of April 5, 2016 and all of its exhibits, as well as this response of April 25, 2016 (POINTS 1 through 19, and EXHIBITS A through G), clearly prove with absolutely NO doubt that the Defendants did in fact show WILLFUL INTENT to DEFRAUD The Plaintiff Dr. MS. The Plaintiff Dr. MS will NOT sue for all the damages (such as the costs of being almost 3 months behind on building her dream home, month-to-month apartment rent, storage of her possessions, mental anguish, loss of earned interest in her retirement account because the Defendants have not refunded her money, etc.) if [redacted] immediately and fully refunds $64,840 of the $67,714.96 total. The Plaintiff Dr. MS has deducted the amount of commission the Defendants paid Ms. [redacted]. If the Defendants [redacted] and [redacted]/USS-Panel/Unlimited Structural Solutions, LLC/Universal Safety Solutions Corporation do not immediately refund at least $64,840 of her $67,714.96 total, which The Plaintiff Dr. MS would gladly accept from the Defendants’ lawyer, The Plaintiff Dr. MS will have no choice but to pursue all legal remedies available to her. There is no doubt that in the face of all this evidence, any judge or jury would find for The Plaintiff Dr. MS. It is strongly advised that the Defendants take this offer of a reduction to $64,840 in the refund to The Plaintiff Dr. MS and get her a check immediately. Respectfully submitted, Dr. [redacted] J. [redacted] FACD, FICD, FASGD, FGSA, DABSCD, FAGHE
Regards,
[redacted]