UNITED STATES FEDERAL COURT
DISTRICT OF MASSACHUSETTS
JUDY E. MORRIS, MD )
)
Plaintiff ) Civil Action No. CA 98-30204 FHF
)
v. )
)
UNUM CORPORATION OF AMERICA, )
et al. )
Defendants
AFFIDAVIT OF JUDY E. MORRIS, MD, PLAINTIFF IN OPPOSITION
TO MOTION TO DISMISS THE COMPLAINT AGAINST UNUM AND ROBERT
A. CRISPIN (PURSUANT TO FRCP 8 and FRCP 12(F)
I, Judy E. Morris, MD, being a citizen of the Commonwealth of
Massachusetts, under pains and penalties of perjury do hereby
strongly oppose the motion put forth to dismiss the above complaint
pursuant to Fed. R. Civ. P, Rule 8 and Fed. R. Civ. P, Rule 12 (f) filed
by Patricia M. Peard, counsel for UNUM and certain other defendants.
1. Local Rules of Court 7.1(a)(2) requires the Court Clerk to strike
any pleadings or motions not accompanied by certification of personal
consultation. (Exhibit A). Plaintiff states under pains and penalties
of perjury that she never received a phone message from Patricia A.
Peard on December 13, 1998 to confer about a Motion to Dismiss.
Plaintiff does recall receiving a phone call but there was silence on
the other end and she hung up after about 20 seconds. That may have
been around the time Ms. Peard claims to have called. The reason
plaintiff remembers this particular call is because she was in a bad
mood and when no one answered on the other end after she asked several
times, she slammed the phone down hard, only to be worried that she
might have damaged someone^Òs hearing. No one called back. Even if
Attorney Peard insists she left one phone message, and she did not hear
back from plaintiff, this hardly fulfils Rule 7.1(a)(2) for attempting
^Óin good faith to resolve or narrow the issues^Ô considering that UNUM
received this lawsuit October 23, 1998 and has had two months to attempt
to confer with plaintiff.
2. UNUM, and Mr. Crispin, in their capacities as employees and
executives of UNUM Corporation have had numerous notices of the bases of
Plaintiff^Òs claims. Please see Attachments B ^Ö Letter dated July 13,
1997 ^ÓTHIS LETTER IS OFFICIAL NOTIFICATION THAT UNUM CORPORATION IS
ENGAGING IN CRIMINAL ACTIVITY TO AVOID PAYING LEGITIMATE CLAIMS FOR
PEOPLE WITH CHRONIC ILLNESSES,^Ô
Attachment C ^Ö Demand letters from Plaintiff to Margaret Fast ^Ö UNUM
Counsel dated October 26, 1997 and November 10, 1997.
3. Ms. Peard is trying desperately to change the focus of Dr. Morris^Òs
lawsuit by introducing feigned issues and it is Plaintiff^Òs informed
belief that UNUM has never had any intention of having any meaningful
discussions with plaintiff, nor consider the allegations plaintiff has
set forth in this lawsuit. This is evidenced by the fact that when UNUM
received word that the filing of plaintiff^Òs lawsuit was imminent, only
then did they attempt to meet and confer. See Attachment D ^Ö Letter
from UNUM Counsel Ann Courtney. Plaintiff had readily agreed to this
meeting as shown by her response ^Ö Attachment E.
However when UNUM realized plaintiff felt the issue was not the denial
of her disability benefits (the issue UNUM wants to focus on) but the
WAY in which UNUM goes about denying plaintiffs^Ò benefits by impugning
plaintiffs^Ò characters to their physicians and employers, and that the
plaintiff contends by information and belief that UNUM is engaging in a
widescale conspiracy to fraudulently deny legitimate benefits and force
plaintiffs to try to sue, UNUM unilaterally cancelled the already agreed
upon meeting ^Ö Attachment F ^Ö Second letter from Ann Courtney.
4. As to the factual and legal morass Ms. Peard claims plaintiff had
led UNUM to; if anyone would carefully read this complaint, it is
patently obvious that, in fact what plaintiff has done is to
systematically discover and expose a widespread conspiracy by UNUM to
fraudulently deny legitimate disability claims by implausible,
ludicrous, fraudulent and feigned issues and reasons for the purpose of
engaging innocent claimants in unnecessary, expensive and emotionally
draining legal battles in violation of 18 USC 1961-1968 RICO and
Massachusetts Insurance Laws. The following cases that have come before
Federal and State Judges clearly illustrate this fact:
Attachment G: From published ruling by Judge Spencer Letts, Case No.
96-0015 JSL, Dishman v. UNUM, US District Court for the Central District
of California
^ÓMr. Dishman^Òs case was referred to the Complex Claims Unit. UNUM
policy requires that there be two ^Ócriteria^Ò present in order for a
referral to be made, one of which is that the ^Ñreserve^Ò for the claim
must exceed $140,000^Å.[and] ^Ówe have exhausted risk management tools at
this time. Ms. Puthoff defined risk management tools as any
investigative or medical review of the claim file. Thus, the referral
to the Complex Claims Unit was based upon the size of the potential
liability ^Å^Å..and the fact that previous investigation and medical
review had indicated no basis for ceasing payments^Å^Å^Å..^Ô ^ÓAlthough
Frankie Puthoff may have been attempting to tell the truth at trial, as
she understood it, I did not credit her testimony in many respects.
Based in part on the lack of credibility of her testimony, and in part
on the court^Òs determination that the ^Ñsuspension^Ò of benefits was made
without any reasonable basis, the Court concludes that UNUM was not
motivated by a legitimate purpose^Å^Å^Å^Å^ÅThe court suspects that the
^Ñsuspension^Ò may well have been intended to place pressure on Mr.
Dishman to settle his claim on favorable terms to UNUM.^Ô
Judge Letts goes on to say ^ÓMr. Dishman has suffered irremediable
harm^Å^Ô ^ÓMr. Dishman was honest and forthcoming with UNUM,^Ô ^Óthe
^Ñsuspension^Ò of Mr. Dishman^Òs benefits has been, if not a calculated
effort, at least an undesirable effort to take advantage of Mr.
Dishman^Òs truthfulness,^Ô and finally
^Óthe facts of this case are so disturbing that they call into question
the merit of the expansive scope of ERISA preemption. UNUM^Òs
unscrupulous conduct in this action may be closer to the norm of
insurance company practice than the Court has previously suspected.
This case reveals that for benefit plans funded and administered by
insurance companies, there is no practical deterrent to unscrupulous
claims practices. Absent such deterrents, the bad faith denial of large
claims, as a strategy for settling them for substantially less than the
amount owed, may well become a common practice of insurance companies.^Ô
^ÓThe Court is appalled by how UNUM handled Dishman^Òs Claim. When UNUM
decided to discontinue Dishman^Òs disability payments, it had no concrete
knowledge about his financial situation. It had no reason to believe
that Dishman and his wife had any means of support other than his
monthly benefit^Å. The decision to suspend payments was made on such
clearly pretextual bases, that it is impossible to avoid the conclusion
that it made in bad faith (sic).^Ô ^ÓThat UNUM^Òs coercive bargaining
strategy did not succeed is entirely due to Dishman^Òs unique ability and
willingness to persevere^Å.Most person^Òs in Dishman^Òs position would not
have had the legal sophistication or financial ability to wait for the
bad faith denial to be redressed by a court. Their only option would
have been to settle on terms very favorable to the insurance company,
because of the financial jeopardy in which the insurance company^Òs bad
faith denial had placed them.^Ô
Note that Plaintiff^Òs claim was also handled by Frankie Puthoff of
the Complex Claims Unit, the same adjuster as claimant Dishman. Ms.
Puthoff and others ordered extensive credit, and financial reports on
claimant from 3 agencies, noting plaintiff^Òs very modest financial
reserves, and UNUM did a background check on Plaintiff^Òs father. This
information was illegally obtained under the Federal Credit Reporting
Act (FCRA). See Yang v. Geinco, DC Docket No 1:35:CV-3287-JOF.
Plaintiff^Òs denial was also clearly pretextual as evidenced from her
doctor^Òs records contrasted with the letters written by Medical
Directors Pringle and Mirkin of UNUM and the fact that during the sham
appeals process UNUM completely ignored all further evidence submitted
by plaintiff and refused to answer her questions about how she could
prove her claims to them.
Att. G-1: Credit/Background checks on plaintiff and her father
Att. G-2: Examples of plaintiff^Òs medical records submitted to UNUM
before her claim was denied and information from Centers for Disease
Control and National Institutes of Health.
Att. G-3: Letters written by UNUM^Òs Dr. Pringle and Dr. Mirkin
supposedly relating telephone conversations they had with plaintiff^Òs
doctors but in fact containing half-truths, fabrications, defamatory
generalizations, and innuendoes. Note also that, according to Maine
Law, holding oneself out to be a ^Ódoctor^Ô or an ^ÓM.D.^Ô in this context,
constitutes the Practice of Medicine. Dr. Mirkin does not have a
medical license in Maine or Massachusetts and should be indicted for
practicing medicine without a license in two states. Dr. Pringle,
although licensed in Maine, is not licensed in Massachusetts and should
be indicted for Practicing Medicine without a license in Mass.
Att. G-4: Rebuttal letters written to UNUM by plaintiff^Òs doctors in
response to the above letters objecting to UNUM^Òs diagnosis of
psychiatric disorders and re-iterating that plaintiff is disabled by
Chronic Fatigue Syndrome.
Att. G-5: Further information submitted to UNUM during appeals process
from Dr. Richard Glew, Infectious Disease specialist, and Dr. Nancy
Klimas, CFS Specialist and Immunologist at the University of Miami, and
lab tests confirming the diagnosis.
Att. G-6: Further letters from Plaintiff^Òs doctors clarifying their
positions with regards to plaintiff.
Att. G-7: Letter from Dr. Morris to UNUM offering to undergo the therapy
UNUM^Òs Dr. Pringle suggested would cure her. Dr. Pringle declined
Plaintiff^Òs offer.
Attachment H: Comments of Federal Judge Hon. Jed S. Rakoff, Paciello v.
First UNUM, 96 Civ. 3206JSR, US District Court Southern District of New
York, date October 24, 1996:
^ÓUNUM has been placed on notice by more than one district court as to
the inadequacies of the denial letter that it still persists, so far as
the record before this court indicates, in using.^Ô ^ÓUNUM, having been
repeatedly informed prior to issuing the particular denial letter in
this case that that denial letter did not as a matter of normally
suffice, nonetheless chose, whether through negligence or otherwise, to
use that form in this case and therefore must be deemed to have waived
any claim that this is a legally adequate letter.^Ô ^Óif the company
hasn^Òt formulated an adequate letter by now, they are in very deep
trouble^Ô The plaintiff^Òs attorney points out that ^Óbecause the
insurance company has put themselves in a position where they stand to
gain by continually flouting the regulation that was designed to make
sure that lay people^Åunderstand exactly what the claimed reason for
disability is and^Åsets out the specific information that that lay person
would be able to provide the company with according to the company^Å.and
that ^Óthere^Òs really nothing in this record that I have that indicates
that the company has ever reversed a decision with respect to a chronic
fatigue syndrome claimant.^Ô
Judge Rakoff states ^ÓIt is not^Åappropriate for a company to take a more
skeptical view when confronted with that kind of claim than confronted
with a claim of someone who has lost all his or her limbs..^Ô and that
^ÓThe company^Òs conduct here^Åis not one that invites judicial
confidence. There is a term that comes up in corporate criminal
sentencing where the court is asked to make a determination whether a
company is a ^Ñgood corporate citizen.^Ò If that question were before me,
which it^Òs not, I would find strong reason to question whether the
defendant by whatever name it now calls itself has been a good corporate
citizen.^Ô
Plaintiff Morris would like to put this question before the court and
ask for Rule 11 Sanctions against UNUM for the inadequacy of their
denial letters, their pretextual denials of disability claims, and the
mere appearance of an appeals process. A copy of plaintiff^Òs denial
letters and her pleas to UNUM to clarify these denial letters are herein
attached as Attachments I, J, K and L.
Attachment M: Comments of Arizona Superior Court Judge Steven D. Sheldon
in the case of Russell v. UNUM, No. CV 95-12521. After UNUM refused to
produce documents it had been ordered to produce by the Arizona Supreme
Court, Judge Sheldon appointed a Special Master to hire a computer
specialist to test ^Óthe availability of information on the Defendant^Òs
computer system^Ô and to determine ^Óif there have been willful,
intentional, or misleading responses to discovery requests or
interrogatories of the Plaintiff.^Ô
Attachment N: Example of UNUM^Òs abuse of the discovery process in the
case of Retha Wellons and UNUM^Òs total lack of response by invoking
generalized but unproveable and irrational defenses of relevance,
attorney-client privilege, work product doctrine and vagueness and
ambiguity defenses for the sole purpose of harassment, delay and
obstruction of justice.
5. Plaintiff also restates and incorporates as if set here in full
the Opposition to Dismissal as set forth in previous Opposition to
Motion to Dismiss filed by Thomas H. Hayman, counsel for Betty Rae Poppo
and previously mailed to the court and all defendants and their counsel
regarding opposition to Rule 8(a) and its attached RICO Complaint and
statement of claim. ^ÓIf the complaint is sufficient under FRCP 8(a),
8(e), and 9(b), the plaintiff should file a response to defend its
complaint. Firestone, 76 F.3d at 1207-08. Plaintiff if filing this
response in defense of her complaint. As to FRCP 12(b)(6), the response
should demonstrate how the facts alleged in the complaint support the
essential elements of the claims. It should emphasize the disfavored
nature of FRCP 12(b)(6) motions, and the liberal pleading policies of
the FRCPs. The plaintiff may also wish to stress case law stating that
the standard on a FRCP 12(b)(6) is so stringent that a court will rarely
encounter circumstances that justify granting such a motion. Mahone v.
Addicks Util. Dist., 836 F.2d 921, 926 (5th Cir. 1988).
Plaintiff concedes that certain parts of her complaint are repetitive
but that none is removed from the ^Óheart of the claim.^Ô The other cases
and legal citations as demonstrated above by comments from judges have
everything to do with the stated claims. There does not appear to be
any absolute page limit to initial complaints in the FRCP or Local Rules
and therefore as a matter of law, plaintiff^Òs complaint cannot be
dismissed merely because of the number of pages.
Furthermore it must be kept in mind that a dismissal under failure to
state a claim upon which relief can be granted would have to be ^Ótreated
as one for summary judgement,^Ô and ^Óall parties shall be given
reasonable opportunity to present all material made pertinent by Rule
56. Plaintiff must be given the opportunity to present sworn affidavits
from other UNUM claimants and attorneys of UNUM claimants as well as
affidavits from her doctors, which she is currently working on
collecting, as well as the opportunity to conduct some kind of discovery
against defendants and to request admissions and conduct
interrogatories. In the absence of this justice will not be served.
6. The victims not known to plaintiff are known to UNUM as they all
are UNUM policyholders, claimants, or attorneys who represent clients
with claims against UNUM.
7. Dr. Morris never had a crusade against the insurance industry.
She became a victim of insurance industry abuses. She did extensive
research, both into legal definitions, the insurance industry, and made
contact with other UNUM claimants. Based on information and belief
gained in this way, Dr. Morris feels duty bound as a physician and a
human being to warn others of what she feels she can prove is a
conspiracy to deny benefits and then obstruct justice by UNUM Insurance
Company. It is certainly true that Plaintiff wishes to contact more UNUM
claimants. The attempts of attorneys such as Lee Hoffman, representing
claimant Steve Russell, to establish UNUM^Òs pattern by using the
discovery process has led to repeated delays and deceptions on the part
of UNUM to produce the material, so much so that Judge Sheldon has
appointed a special master to investigate his suspicions that UNUM is
not being truthful in the discovery process.
8. This complaint does not violate Fed. R. Civ. P. 12(f). Although
there is some repetition, some is necessary due to the particularity
requirement of the pleadings. However very little, if any, of this
complaint is immaterial or impertinent as it all goes to support the
general allegations that UNUM and the other defendants are using
criminal activity to put their own financial well-being ahead of that of
their policyholders and claimants. If it were not submitted in the
initial complaint, almost all of this information would have to be
submitted in further motions, requiring repetitive efforts on the part
of plaintiff and extra time from the court to process and read the
information as motions and briefs. Dr. Morris is not attempting to
impugn anyone^Òs character who has not impugned themselves, as evidenced
by at least 3 judges. She has evidence that UNUM is aggressively
putting their own financial well-being ahead of the financial and
physical well-being of plaintiffs in such a way as to have wanton and
willful disregard of the unreasonable risks to claimants physical and
emotional well-being even if there is no actual intent to kill or
injure. This constitutes malicious intent and is evidence of a ^Ódepraved
heart.^Ô Attachments O and P ^Ö Excerpts from UNUM^Òs 1996 and 1997 Annual
Reports both address the fact that as part of its ^Ónormal course of
business operations^Ô a number of lawsuits are pending, including ^Óclaims
for punitive damages^Ô but that UNUM does not expect these lawsuits to
have a ^Ómaterial adverse effect on the consolidated financial
position..of UNUM.^Ô The second page details how benefits and expenses
for the Disability Line peaked in 1995 but have decreased by $84 Million
and $133 Million in the two subsequent years. Attachment Q is a
newspaper article quoting both James F. Orr, III and Robert W. Crispin,
proudly declaring UNUM^Òs financial performance and comeback due to
^Óaggressive steps^Ô and ^Ócorrecting problems that have depressed earnings
in its core disability line.^Ô Attachment R demonstrates how UNUM did
this by tying employee bonuses to meeting the companies^Ò financial goals
and earnings per share which thereby enriches corporate executives as
shown by their salaries and stock holdings, thereby setting up a
competitive atmosphere among claims adjusters and other employees to
deny or terminate benefits, with the executives being the ultimate
beneficiaries of these actions. This clearly goes to the corporate and
individual state of mind in creating and allowing this racketeering
enterprise within UNUM and making no effort to stop it.
9. As far as the references to UNUM driving claimants to suicide,
plaintiff just learned two days ago that a second claimant, named in her
lawsuit, Victim No. 2, Dr. Werner Aeschlimann, a Massachusetts
physician, committed suicide during the course of his lawsuit against
UNUM to collect benefits he felt were rightfully owed him. Dr.
Aeschlimann^Òs attorney refused to tell plaintiff if the grieving family
was able to collect a settlement consistent with the amount Dr.
Aeschlimann would have received if he had continued living, citing
attorney-client privilege. Plaintiff should be allowed to obtain this
information from UNUM during the discovery process.
Attachment S are E-mail discussions between plaintiff and two UNUM
claimants. Scotsman is the computer name for Steve Peteet who committed
suicide in July 1998. Auggie is Roger Liska, a claimant who has
expressed frequent suicidal ideation related to oppression from UNUM.
During discovery plaintiff hopes to obtain evidence to show that the
deaths of these two men resulted in UNUM paying out substantially less
than it would have, had the claimants lived,
as well as the harassment, intimidation and defamation these men were
made to endure.
Fed. Rul. Civ. P. 8(e)(2) states ^Óa party may set forth two or more
statements of a claim ^Å.alternately or hypothetically, either in one
count^Åor in separate counts^Å^Ô Fed. Rul. Civ. P. Rule 11(b) elaborates
on this by saying ^Óan attorney or unrepresented party is certifying that
to the best of the person^Òs knowledge, information, and belief, formed
after an inquiry reasonable under the circumstances, -
(2) the claims, defenses, and other legal contentions therein are
warranted by existing law or by a nonfrivolous argument for the
extension, modification, or reversal of existing law or the
establishment of new law; and
(3) the allegations and other factual contentions have evidentiary
support or, if specifically so identified, are likely to have
evidentiary support after a reasonable opportunity for further
investigation or discovery.^Ô
Plaintiff maintains she has scrupulously followed Rule 11 and, but
for delays and discovery abuses she contends, by knowledge, information
and belief that UNUM and the other defendants^Ò attorneys will engage in,
she would have absolutely no difficulty conclusively proving all of the
allegations in her complaint far beyond a preponderance of the evidence.
Ms. Peard would attempt to usurp the justice system by asking the
Court to dismiss plaintiff^Òs complaint because the Plaintiff^Òs
allegations are horrible and disturbing. However plaintiff maintains
she has the legal right, and a moral duty, according to the constitution
and the 7th amendment to present her evidence to a jury and let them
decide if the actions of UNUM constitute those of a company that has a
^Ódepraved heart,^Ô an indifference to the value of human life.
10. When considering defendant^Òs motion, the court must construe the
factual allegations in the light most favorable to plaintiff with all
doubts resolved in the pleaders favor and the allegations taken as
true. In re Stac Elecs.Sec. Litig., 89 F3d 1399, 1403 (9th Cir, 1996);
Doe v. Hillsboro ISD, 81 F 3d 1395, 1401 (5th Cir. 1996). Only if no
possible construction of the alleged facts will entitle plaintiff to
relief should the court grant defendant^Òs motion. Hishon v. King
Spalding, 467 U.S. 69, 73, 104 S.Ct. 2229, 2232 (1984); Conley v.
Gibson, 355 U.S. 41, 45046, 78 S.Ct. 99, 102 (1957). If the factual
allegations in plaintiff^Òs complaint support any legal theory that
entitles plaintiff to some relief, the court should overrule defendant^Òs
motion.
11. Plaintiff begs the Court to strike in their entirety all of
these defendants^Ò motions to dismiss, but in particular this one from
Pat Peard as she clearly did not make a good faith effort to confer with
plaintiff before filing this motion. At best, and plaintiff asserts
that this did not even occur, Ms. Peard left one message on plaintiff^Òs
answering machine. This is further evidence that it is and always was
UNUM^Òs and their attorneys^Ò intention to deal with this and other
claimants in Bad Faith on a systematic basis as detailed in plaintiff^Òs
complaint. Plaintiff still contends that all defendants should be able
to make responsive answers to the charges in this lawsuit. In all
likelihood and based on Plaintiff^Òs knowledge and experience they are
merely going to deny all material allegations anyway, so the purpose of
requiring plaintiff to rewrite and resubmit this lawsuit is purely to
delay her efforts to get the true questions of fact before a jury. Many
of these questions will be resolved in plaintiff^Òs favor by summary
judgment after she has had the opportunity to conduct discovery and
obtain and submit affidavits to the Court.
12. Plaintiff has sufficiently alleged facts necessary to prove each
element of her causes of action and defendants motion should be denied.
Plaintiff^Òs stated claim for relief is entitled Prayer for Relief and
can be viewed in Paragraph 119, page 282 of the Complaint as clearly
stated in the Contents, Page 3 of the Complaint. All defendants are
jointly and severally liable for the damages by virtue of their part in
the ongoing conspiracy of selling or offering fraudulent insurance
policies and/or failing to act within their occupational, contractual
and fiduciary duties to plaintiff and the public when the fraud is
discovered and reported to them in good faith by the victim.
REQUEST FOR ORAL ARGUMENT
as per Local Rule 7.1(D)
To avoid the necessity of filing and responding to multiple
time-consuming and meritless motions of this type, plaintiff, for the
second time, respectfully requests a meeting of counsel representing all
defendants and the plaintiff with a court officer or judge at the
earliest possible time to establish the ground rules for this litigation
including the requirement of all parties to avoid filing unnecessary
motions, incurring unnecessary costs and delays, and to establish
appropriate penalties and sanctions for parties that do not abide by the
rules set up by this court.
Plaintiff incorporates and restates previous request for oral
argument as if set forth herein in full.
Signed under the penalties of perjury this 3rd day of January, 1998.
Judy E. Morris, MD
PRO SE
CERTIFICATE OF SERVICE
I hereby certify that a true copy of the above document was
delivered in person January 4th, 1999 to US District Court, District of
Massachusetts, Springfield and served by United States Postal Mail,
postage prepaid upon the following attorneys representing all defendants
in Morris v. UNUM, et al. Mailed on January 4th, 1999.
Judy E. Morris, MD
PRO SE
Patricia A. Peard, Esq. representing ^ÓUNUM^Ô claimants
Bernstein, Shur, Sawyer
& Nelson, PA
100 Middle Street, PO Box 9729
Portland, ME 04104-5209
Katherine A. Robertson, Esq. ^ÓUNUM^Òs^Ô local counsel
Buckley, Richardson & Gelinas
1500 Main Street
PO box 15507
Springfield, MA 01115
William J. Kayatta, Esq. representing Robert Crispin
Geraldine G. Sanchez, Esq.
Pierce Atwood
One Monument Square
Portland, ME 04101
H. Gregory Williams representing State of Mass.,
Assistant AG Harshbarger, Melconian, DOI,
Office of Attorney General Ruthardt, Goetz, Marcinkus,
Western Mass. Division Marquez
436 Dwight Street
Springfield, MA 01103-1317
Tracy L. Devlin, Esq. representing IFB and Michael
E. Michael Sloman, Esq. Gray
Meyer, Connolly, Sloman
& MacDonald, LLP
12 Post Office Square
Boston, MA 02109
Thomas H. Hayman, Esq. representing Betty Rae Poppo
Cetrulo & Capone, LLP
53 State Street
Exchange Place
Boston, MA 02109
Robert Pierce, Esq.
Gretchen A. Brodnicki, Esq. representing Harrington and
Pierce & Mandell, PC Mangion
11 Beacon Street, Suite 800
Boston, MA 02108-3002
Christopher N. Jones Co-Counsel for Transunion
Marion, Satzberg, Trichon, Credit Corporation with Pat
Kogan & Wertheimer, PC Peard
3000 Mellon Bank Center
1735 Market Street
Philadelphia, PA 19103-7640
Carolyn G. Sullivan representing Jack Taylor
Melick & Porter, LLP
28 State Street
Boston, Massachusetts 02109
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Created: January 6, 1999
Last Updated: May 28, 2000