CASE DIARY ON JUDY MORRIS V UNUM ET AL.




   
   October 20, 1998
        - Lawsuit complaint filed against
          UNUM and 59 other defendants. Cost $150 dollars.

   October 23, 1998
        - Recieved letter from UNUM attorney Ann Courtney
          dated 10/21/98 requesting we meet in person.

   October 26, 1998
        - Response to UNUM's letter of 10/21/98.
          I sent, certified return reciept, an answer to Ms.  Courtney
          telling her I will meet with her on November 25, 1998 in Monson 
          and insisting that I be allowed to videotape the proceedings.

   October 28, 1998
        - Copies of lawsuit and form called Waiver of Service mailed
          certified, return reciept to all defendants.  The purpose of the
          Waiver of Service is to set the tone of the litigation and avoid
          having to hire deputies and others to deliver the lawsuit with a
          summons.  Cost for duplication and mailing - about $1000.

        - I called all agencies involved that had defendants (PI Agencies, 
          etc.) to make sure the defendants were still employed there so they 
          can't claim the person no longer works there and they have no idea of
          their whereabouts.  I did this for the three PI agencies, the
          Insurance Fraud Bureau, and also found out the names of the
          Directors of these agencies.  Also while I was speaking with the
          secretary of the Insurance Fraud Bureau, I specifically 
          asked her if this agency is responsible for investigating fraud in
          health claims.  My state senator Senator Brewer had tried to tell
          me this agency was only responsible for Automobile Insurance Fraud.
          The secretary gave me a definite yes and in fact stated that a lot
          of their work involves Workman's Comp.

        - Today I got a telephone call from Dan Skelly who tells me that
          he is the Director of the Massachusetts Insurance Fraud Bureau.
          He agreed to be tape recorded and I am going to
          transcribe the conversation here.

   November 20, 1998

        - Received letter dated 11/16/98, from
          Ann Courtney of UNUM, now refusing to meet with me, and
          directing me to another attorney.

   November 21, 1998

        - Responded to the new attorney cited in MS. Courtney's letter
          by a letter dated 11/21/98.
 
   November 24, 1998

        - Today's talk with UNUM's attorney


  November 25, 1998

        - The court recieved a Motion to Allow Patricia A. Peard of a
          Portland Law Firm to practice in Massachusetts for this case.

  November 28 , 1990

        - Affidavit in Response to Peard's Motion


  December 1,2 or 3, 1998
        -  Receipt of Peard's motion annotated:

                11/30/98 Allowed Freedman, S.J. and the Court Clerk.


  December 2, 1998

       - I did have a telephone call with Attorney Hayman, who filed
         a motion to dismiss the entire case because it was not "short and
         plain" and "concise and direct".

  December 3, 1998

       - Hayman files Motion to Dismiss

  December 7, 1998

       - My Response to Hayman's Motion to Dismiss
       - A motion was dated December 7, stamped received by the clerk's
         office on Dec. 9, filed by attorneys for Robert Crispin - one
         of UNUM's Board of Directors to allow TWO Portland, Maine attorneys
         to practice in Massachusetts.  I recieved a copy of the front of
         this motion December 7, with notation:

              "12/10/98 Allowed, Freedman, G. J."

         Affidavit in opposition was filed along with a letter to the
         Honorable Frank H. Freedman on December 14, 1998.

       - Notes on Poppo/Hayman's Motion

  December 9, 1998

       -  Completion of all service

  December 10, 1998

        - Letter from
                     H. Gregory Williams
                     Assistant Attorney General
                     Director of Defensive Litigation
                     Western Massachusetts Division
                                                                                    
  December 12, 1998

        - Reply to previous letter from Mr. Williams

  December 12, 1998

        - Date of UNUM's Motion to Dismiss

  December 14, 1998

        - Letter to:
               The Honorable Judge Frank H. Freedman
               United States District Court
               District of Massachusetts

  December 17, 1998

        - Dated Harrinton Hospital's Motion to Dismiss
          Preceded by commentary.

  December 19, 1998

        - Diary Entry
          Trip to Washington, D.C.

  December 24, 1998

        - Diary Entry
          Victim #2, Dr. Werner Aeschlimann dead of suicide

  December 23, 1998

        - Dated MA IFB's Motion to Dismiss

  December 25, 1998

        - Diary Entry
          UNUM's Suicide Victim Number 2.

  December 28, 1998

        - Undated MA AG's Motion to Dismiss

  January 01, 1999

        - Letter to Robert Pierce, Attorney for Harrington Hospital

  January 02, 1999

        - Letter to Patricia Peard, Attorney for UNUM
          regarding my request from the court for a preliminary injunction
          requiring back payment owed me.
          This dialog continues below at January 12, 1999.

  January 03, 1999

        - MOTION IN OPPOSITION TO UNUM's MOTION TO DISMISS
          http://graham.main.nc.us/~bhammel/INS/DOCS/motop010399.html

  January 04, 1999

        - MOTION IN OPPOSITION TO IFB's MOTION TO DISMISS
          Opposition to Insurance Fraud Bureau Motion to Dismiss
          http://graham.main.nc.us/~bhammel/INS/DOCS/motop010499.html

  January 06, 1999

        - MOTION IN OPPOSITION TO HARRINGTON HOSPITAL'S MOTION TO DISMISS
          http://graham.main.nc.us/~bhammel/INS/DOCS/motop010699.html

        - Diary Entry
          A talk with Ron Diamond & notes on confidentiality agreements.

  January 07, 1999

        - Diary Entry
          Synopses of Letters to Government & their Responses.

  January 08, 1999

        - Diary Entry
          with a copy of a letter hand delivered to

               H. Gregory Williams
               Assistant Attorney General
               Western Massachusetts Division

  January 11, 1999

        - MOTION IN OPPOSITION TO MOTION TO DISMISS BY AG, et alia

  January 12, 1999

        - Letter from Patricia Peard, Attorney for UNUM
          and My response to it.
          
  January 28, 1999

        - ORDER TO SHOW CAUSE
          TO ENJOIN UNUM INSURANCE TO
          SPECIFIC PERFORMANCE OF CONTRACTS AND TEMPORARY
          RESTRAINING ORDER PURSUANT TO FED.RUL. CIV. P. RULE 65
          [Also See Addendum 02/04/99]

        - LETTER
          From P. Peard regarding the following Motion.

  January 29, 1999

        - MOTION
          TO DISQUALIFY UNUM'S COUNSEL, P. PEARD

  February 04, 1999

        - ADDENDUM TO THE
          ORDER TO SHOW CAUSE of
          01/28/99

  February 05, 1999

        - MOTION TO DISMISS
          by Jack Taylor

  February 06, 1999

        - DIARY and LETTER
          Ms. Sullivan and Mr. Taylor

  February 08, 1999

        - DIARY ENTRY
          Thoughts and Feelings about the upcoming Hearing.

  February 19, 1999

        - [Judicial Hearing Scheduled on Motions and Counter Motions]
          10:00 AM before Judge Frank H.Freedman, Springfield Federal
          District Court, Springfield, MA.

        - Memorandum and Order by Judge Freedman

  February 21, 1999

        - DIARY ENTRY
          Judydoc Meets The Judge

  February 24, 1999

        - DIARY ENTRY
          The Speech I wanted to give in court

  March 15, 1999

        - The Ammended Complaint
          filed pursuant to Memorandum and Order of February 18, 1999.
         
  April 01, 1999

        - The Second Filing of Order to Show Cause from 01/28/99.

  April 14, 1999
        - DIARY ENTRY - Emotional Distress

  April 22, 1999
        - DIARY ENTRY - GoodNew/BadNews

  April 28, 1999
        - DIARY ENTRY - Discovery Conference
          Discovery Conference Scheduled - Could use pointers

  May 03, 1999
        - DIARY ENTRIES - April 28 through May 3
          Discovery Conference Correspondence

  ------------------------------------------------------------------------

  May 25, 1999 - July 16
        - UNUM.Provident Merger
          Procedings of such Unparalleled Blatant Corruption of the
          Governmental Officials of the State of Maine, that defies
          any sense except in a Totalitarian Fascist State.

  ------------------------------------------------------------------------

  May 28, 1999
        - DIARY ENTRIES - A quick note:
          the Federal case and the UNUN/Provident Merger.

  June 6, 1999
        - FIRST DISCOVERY DEMAND FOR DOCUMENTS TO UNUM
        - INTERROGATORIES TO UNUM

  July 21, 1999
        - UNUM'S RESPONSE DOCUMENT DEMAND OF June 6, 1999
        - UNUM'S RESPONSE INTERROGATORIES OF June 6, 1999
        - DR. MORRIS'S RESPONSE DOCUMENT DEMAND
        - DR. MORRIS'S RESPONSE INTERROGATORIES

  ------------------------------------------------------------------------
  July 26, 1999
        - Meanwhile, the: UNUM - CDC Connection
  ------------------------------------------------------------------------

   September 5, 1999
        - LETTER
          To P. Peard
          RE: Conference: Plaintiff's responses to UNUM Discovery
          Requests Information regarding deposition September 22, 1999.

  ------------------------------------------------------------------------
   May 15, 2000
        - MEMORANDUM AND ORDER
          By Judge Freedman.




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The URL for this document is:
http://graham.main.nc.us/~bhammel/INS/diary.html
Created: October 24, 1998
Last Updated: May 28, 2000