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1. Your Honor, I never forged Ms. Chen’s signature. 2. Several of the forged signatures in the document were forged by my assistant Mandi Li. 3. I had an assistant, Mandi Li she worked for me between September 2017 to May 2021. 4. Regarding the forged signature, MassMutual officially notified Ms. Chen that Mandi Li forged her signature. 5. After I learned Mandi Li forged Ms. Chen’s signatures, she was immediately terminated. 6. This is a long story, Your Honor, I will try my best to restore the whole process of things. 7. The first time I met Ms. Chen was on December 11, 2019. Ms. Chen came to my office and brough two life insurance policies she purchased from American General and National Life insurance companies. During that meeting, Ms. Chen told me that she had no confidence in the two insurance policies in her hand because those two policies may lapse in the future. Ms. Chen said she wants a guaranteed death benefit that never lapses. She also told me, she is a single mother, she wants long term care policy. (Attachments: AGLA IUL policy & Old National Life policy) 8. I met Ms. Chen again on December 17,2019. I suggested Ms. Chen consider Whole Life insurance with long term care rider from MassMutual, because whole life product has guaranteed cash value and guaranteed Death Benefit. I reviewed whole life policy with Ms. Chen. Ms. Chen decided to purchase whole life policy form MassMutual. She signed application on that day. I saw her sign the application in front of me. But she asked to hold the application until the new Year. (Attachment: Application signed on 12/17/2019.). 9. On January 02, Mandi Li submitted application which Ms. Chen signed on December 17, 2019. 10. On January 06, Ms. Chen did physical exam. (Attachment APPS record show examiner completed) 11. On January 15, MassMutual approved Ms. Chen’s application with Select Preferred rating which is pretty good rating. Mandi noticed Ms. Chen. Ms. Chen asked to hold it. (Attachment rating offer dated 01/15/2020) 12. On February 12, 2020, at 2:00pm, Ms. Chen came to my office. She was happy with the rating MassMutual offered. Ms. Chen decided to continue to purchase whole life policy and she wants to do 1035 exchange. Then I ask Mandi Li bring Ms. Chen to other room to complete that paperwork. Later Mandi Li came back to my office told me Ms. Chen signed the paperwork but ask to hold it. Ms. Chen told Mandi she wants to know her National Life policy's performance before initiating the 1035 exchange. I told mandi to hold the 1035 exchange process until Ms. Chen notice her to do it. 13. Ms. Chen came to my office on next day, which is on February 13, 2020. She called with Mandi Li to National Life to request an in-force illustration. 14. on February 21, 2020, Mandi Li submitted the paperwork. Mandi Li later told me (after the MassMutual’s investigation, Mandi sent me email) she had seen Ms. Chen sign the forms, but on February 21, when she needs to submit the paperwork, (because of Covid 19 work at home,) she couldn’t find the documents previously signed by Ms. Chen, so, she forged Ms. Chen’s signature in order to submit the paperwork to MassMutual. Please see the email Mandi Li send to me on May 19, 2021. (Attachment: application and Mandi Li’s email and the copy of replace letter Rong Shen send to GA) 15. After Mandi Li submit the paperwork, I received multiple communication form Ms. Chen. She asked me to proceed with the replacement. 16. On February 27,2020, Christine Chen sent me the National life policy inforce illustration via text message. Ms. Chen also required me to proceed with replacement as soon as possible. I replied to her “understood”. (Attachment: National life inforce illustration, Text message copy). 17. On March 03, 2020, the new policy was issued with estimated 1035 Exchange amount is $9,851. 18. On March 06, 2020, MassMutual initiated a 1035 exchange process. (Attachment: MassMutual email: Chen 1035 Exchange start). 19. On March 13, 2020, Christine Chen called me again asked why the replacement process has not finished, her agent from AGLA and National Life kept calling her. She asked me to speed up the replacement. 20. On March 13.2020, MassMutual notified me that MassMutual received 1035 exchange from AGLA, amount is $3,857.27. 21. On March 17, 2020, Christine Chen send signed delivery receipt to Mandi Li ‘s phone. Mandi Li forward pictures to me on April 29,2021. (Attachment: Text message picture, Ms. Chen signed delivery receipt) On May 20, 2020, Mand Li told me that, though Ms. Chen did sign the delivery receipt, she had to use her old signature because the texted pages, when converted to .pdf, were not readable. Please see Mandi Li’s email on May 20, 2020. (Mandi Li’s Email attached) 22. On March 31, 2020, in order to proceed with the 1035 exchange, National Life had a phone call with Ms. Chen. During the phone call she said she wanted to proceed with the 1035 exchange. During that call, National Life asked Ms. Chen whether she authorized National Life to process the 1035 exchange, to transfer the surrender value to MassMutual, and Ms. Chen said yes. If she had not told National Life she wanted the 1035 exchange on the phone, it never would have occurred. 23. On April 03, 2020, MassMutual received $7,684.10 from National Life. 24. On April 16, 2020, I ask Mandi Li contacted Ms. Chen. Because I want to review final illustration with the updated 1035 exchange amount with her. Ms. Chen said concerning COVID-19, no need to meet, she understood the policy, just want to confirm her policy is effective. Mandi Li confirmed her policy was effective. Mandi Li gave Ms. Chen detailed instructions on how to log in to her online account. Mandi Li also provided Ms. Chen MassMutual's customer service line of 800-272-2216 if she had questions. 25. On September 21, 2020, Ms. Chen called me, saying she received a payment notice from MassMutual. Due to COVID-19, her business has no income at all, she doesn't have money to pay the premium now. She was surprised. She thought her next due date is in March next year. 26. On September 24, 2020, Ms. Chen called me, she told me she wants to use 1035 exchange money to continue to pay the premium. 27. On September 30, 2020, Christine Chen came to my office, we discussed several options to use 1035 exchange money to pay the premium. 28. On October 14, 2020, Christine Chen came to my office said the contract shows MassMutual use her 1035 exchange money purchased additional life insurance, this is not she wants, she wants to use this money to pay the premium. 29. On October 21, 2020, Christine Chen called me said I didn't provide 15 years N-Pay illustration. She requested me to print it for her, she would pick it up in my office in the afternoon. She came in the afternoon, and I showed her 15 years of N-pay illustration in the package she brought. She told me she will come back. 30. On December 2, 2020, I received an email from MassMutual home office that Ms. Chen submitted a complaint regarding the policy. Ms. Chen complained that most benefit are non-guaranteed, MassMutual collect 2nd premium 6 month earlier after she transferred money from her old insurance policy, the MassMutual policy is more expensive …...I received MassMutual’s responses on January 29, 2021, said I am not misrepresented the policy, MassMutual unable to honor Ms. Chen’s request to rescind the policy and return the premium she paid. (Attachment: Ms. Chen’s complain and MassMutual’s responses) 31. On March 23, 2021, Ms. Chen sues MassMutual in small claims court, require cancel the policy and ask MassMutual to refund her $11k 1035 exchange money. But later dismisses that case. 32. In April 2021, during the investigation, MassMutual found out that Mandi Li forged Ms. Chen’s signatures. Because of this finding, MassMutual agree to return the entire amount that Ms. Chen paid into the policy which is Ms. Chen asked. But Ms. Chen updated her claim, her lawyer send a demand letter ask for $213k. 33. With respect to the first lawsuit that Ms. Chen filed against MassMutual, MassMutual offered full refund of the 1035 exchange amount $11,541.88 she had asked for, and then Ms. Chen send a demand letter ask for $200k, MassMutual said no, but MassMutual was still prepared to pay her $11k but she has refused to accept the offer. (Attachment: MassMutual’s response letter) 34. Ms. Chen previously dismissed the first small claim lawsuit that she filed, only to refile a new small claims lawsuit a year later, this case. This is the reason I am here. 35. I will be happy to try to work something out with Ms. Chen, but both me, my lawyer, and MassMutual have all tried to communicate with Ms. Chen and she just ignores communications from all three of us. There’s not much we can do if she just ignores us.