bro, just ask for an extension next time—dafuck?

prepare yourselves…
we finally got
their official response ✨
to my complaint.

🥁🥁🎶🎶🎶
🥁🥁🎶🎶🎶
🥁🥁🎶🎶🎶
(drumroll)

and baby…
it’s giving
✨fantasy fiction✨
not legal defense.

✦

🫨🫨🫨
what they actually filed in court:

aka: welcome to the imaginary universe of nm
where accountability and duty do not exist 💕🧚🏻‍♀️✨🍄🧙‍♂️🐉


(affirmative defenses, p. 40–41)

“plaintiff’s claims
are barred because
northwestern mutual
does not owe
a legal duty
to plaintiff.”

🤯💥🧠

✦

🫨🫨🫨
what they actually filed in court:


🧚🏻🧝🏻‍♀️ no duty because no securities were bought” ¶3 🦄✨

and yet 💥—
no securities ≠ no duty.
colorado’s CCPA (C.R.S. 6-1-105)
applies to:
unfair/deceptive insurance practices.

✦

baby,
(lol)
what
the
fuck?

did you even try? 🤯🤯

i mean,
i understand
i’m
pro se ✨
but damn
not illiterate.

💭
side note:
watch how fast
this turns into a blame-game.
corp says “not us, blame the rogue reps,”
reps say “not us, big corp supervised.”
👈✨👉

baby, that’s called implosion. 💀⚡🧨

✦

💥 reality check 💥

✓ broker-dealers
must supervise the activities
of each associated person
under Rule 3110
and keep business communications
under SEC 17a-4.

independent contractor status
doesn’t reduce those obligations.
FINRA has said this
over and over.

✓ the colorado statute is blunt:
any producer
who solicits or negotiates
insurance 🧚🏻‍♀️✨
“on behalf of an insurer”
is regarded as
representing the insurer
(not the customer)
in any controversy.

📌
(y’all said
‘fuck the reps,’
save the firm—
didn’t you?
lmao, i get it)
🤫

✨ that makes the insurer
answer for what its producer did. ✨

✦
and by the way…

💥 inducement = duty 💥

hey, lol,
wuddup, 👋🏼
remember how…

🗣🗣🗣
you recruited
my spouse,

🗣🗣🗣
brought me in pregnant
to fund the dream,

🗣🗣🗣
dissected our finances,
our life goals,
our equity—

🗣🗣🗣
then routed all
paperwork/billing
through me.

lmfao.

baby,
that’s reliance 💥
you engineered.

✓ function over labels.
calling me “not a client”
doesn’t work
when you
treated me as a client ✨
lol. what?

✍️✍️✍️
(signing,
paying,
IRA inquiry,
replacement policy
naming me owner).
¶30–31

🤰💥🥊

✓ dv context matters.
ignoring…
(reviews notes)
entirely,
my dv notices
while leaving control
and ownership
with my abuser—
after taking my
signatures and money—
looks like bad faith
and invites
punitive fucking exposure.

🫨 colorado’s consumer protection act (CCPA)
ever heard of it? lol.
that shit
imposes statutory duties 👏🏻
in the sale of goods/services—
including insurance—
to avoid deceptive
or unfair practices.
you don’t need a
securities account
for that to apply.

⚖️ colorado supreme court cases
lay out the
private-action elements
like in—
hall v. walter
babe,
that shit confirms ✨
the act’s reach
into commercial sales practices 👏🏻
not just “purely private” disputes.
lol.

bro.
insurers and
their producers 💀💥
also face
specific statutory duties:
colorado’s “unfair methods
of competition/unfair
or deceptive practices”
statute (C.R.S. 10-3-1104)
bars misrepresentations, 💫
altered applications
without consent,
and related conduct
in insurance.
lol.

(count ii –
supervisory breach, p. 16–18):
aka: but babe,
you never bought securities. 🤔

🤯🔥

so—
their answer
tries to dodge
🏃‍♂️💨🙄
by saying
NMIS had
no securities relationship,
but they
simultaneously admit
NMIS “had certain
supervisory obligations”
over its reps—
an admission
that undercuts
a broad “no duty” posture.

bro.
pick a fucking lane.
👏🏿👏🏽👏🏻👏🏾👏🏼

anyway✨—

💣 once they
undertook
to service,
baby,
a duty arose
(“assumed duty”
/ negligent undertaking).

😳🔥 colorado recognizes
that when someone
undertakes to
render services
that others will
rely on,
they must do so
with reasonable care
(the “assumed duty” doctrine;
restatement §323).
the colorado supreme court
discusses this
directly
(jefferson cty. sch. dist. v. justus).

💣 their own answer confirms
activity consistent
with an undertaking:
they admit policies
were issued/lapsed
on the dates they claim,
and that an email/FROR
went out about “replacing”
my policy—i.e., they
were actively
steering paperwork
and policy changes.
again, that ain’t
“no relationship.”

😳🔥 so we got—
direct onboarding artifacts—
e.g., the “signature needed –
juvenile life insurance application…”
email flow
showing me
as the signatory.
that is further
evidence
of an undertaking.

💣 insurance agents/producers
owe duties when they procure coverage.

😳🔥 colorado supreme court:
an insurance broker/agent
servicing a
customer’s insurance needs
owes a duty of reasonable care
to procure the coverage requested
or to accurately advise—
classic
bayly, martin & fay v. pete’s
satire.
lol.

so—

💀💥

i was the one signing
medical paperwork,
receiving “signature needed”
links,
and paying lil’ premiums.
that squarely places me
as the
consumer
being “serviced,”
regardless of how
they now try
to label ownership.

💣 supervision & records duties
exist even if a trade
is never executed.

😳🔥 FINRA Rule 3110
requires
member firms
(like NMIS)
to supervise the activities
of each associated person
to 💥 ensure compliance 💥
with securities laws
and FINRA rules.
that includes
how reps communicate
with retail prospects/customers
about potential
securities business
(e.g., like when
i attempted to
rollover my IRA via
insta dm,
[receipt confirmed]
because my
rep. never gave me
her goddamn
phone number.)
don’t worry,
i saved a record,
right before she
deleted
her whole account.
lol.
sucks.
FINRA

🤪🤯

💣 SEC Rule 17a-4
requires broker-dealers
to preserve business-related
communications
(including electronic messages)
“relating to [their] business
as a broker-dealer.”
so like,
off-channel DMs/texts
about prospective
brokerage business
are a
recordkeeping/supervision issue—
recent enforcement underscores this.

😳🔥 their answer’s
own admission
that NMIS had
supervisory obligations,
paired with my
IRA-rollover ask
and the off-channel
communications
i’ve documented,
defeats a sweeping
“no duty” stance.

shit.

💣 domestic-violence context
creates separate statutory guardrails
in insurance.

😳🔥 colorado prohibits
unfair discrimination
and certain disclosures
tied to a person’s
domestic-abuse status
in insurance
(C.R.S. 10-3-1104.8).
given my contemporaneous
notices
and the timelines,
their “we owe nothing” posture
ignores duties not to harm
via discriminatory handling
or disclosures.

💣 “economic loss”/contract-only
defenses won’t kill independent
tort/statutory duties.

😳🔥 colorado’s
economic-loss doctrine
doesn’t bar claims
where there’s an|
independent duty
(statutory or tort).
town of alma v. azco
confirms
the independent-duty rule;
bermel v. blueradios (2019)
emphasizes
that certain
statutory/tort claims
survive.
that matters for
fraud/CCPA/recordkeeping-
based theories.

💣 their timeline admissions +
my docs already show
“consumer” status and reliance.

😳🔥 answer:
“plaintiff paid premiums…
accepted as directed and
authorized by plaintiff”
(admission).
that’s me funding
the products they placed—
consumer relationship and reliance.

their timeline concedes
a replacement process
and communications
into my inbox.
that combined with
my billing notices
(e.g., ****4395 payment reminders)
and the SEC TCR listing
the policy numbers,
it’s obvious
i was treated
as the
paying customer.

💣 fiduciary/confidential relationships
can arise by conduct and reliance.

😳🔥 colorado recognizes
fiduciary duties
where one party
occupies a superior position
and the other justifiably relies
on their counsel—
even outside classic
per se categories
(moses v. diocese of colorado).
so, their
“no fiduciary duty”
assertion
flat ignores
that my facts
(postpartum,
policy procurement,
money flows,
promised IRA assistance,
off-channel steering)
are exactly how
fiduciary/confidential
relationships
are found by juries.

crazy. 💡

✦ bottom line:

their
“no duty to samantha”
absolute fantasy
is contradicted by

(a) their own admissions
of supervisory obligations,
premium acceptance,
and directed communications,
and

(b) colorado law
imposing duties
via the CCPA,
the insurance code,
the assumed-duty doctrine,
and broker-dealer
supervision/recordkeeping
rules when reps
engage you
about securities
(lol that damn IRA rollover)
or insurance.

aka:

sorry babe 💔

inducement = duty.
function > labels.
“no duty” isn’t law.

it’s a fucking bedtime story.

✦

yo—
if you needed
more time,
there is absolutely
no shame in that.

shit.
better than a defense
that’s basically ✨fanfic✨

💀