Judy Morris, MD
      261 Bumstead Rd.
      Monson, MA  01057
      December 12, 1998

H. Gregory Williams
Assistant Attorney General
Director of Defensive Litigation
Western Massachusetts Division
436 Dwight Street
Springfield, MA  01103

Dear Attorney Williams,

Enclosed please find copies of the postal receipts and green cards
proving that I had sent Waivers of Service and a copy of the lawsuit to
Solmaria Marquez, Michael Goetz, and Walter Marcinkus in the same
fashion and at the same time as Waivers and lawsuits were mailed to the
other defendants, around October 27, 1998.  The green cards were
returned to me signed by Tyrone Nesmitt and one was even stamped with
the name Bob Kirkness.  I had every reason to believe these packages
were delivered to the above defendants since they were in the same group
of packages that was accepted by some of the other defendants whom you
are representing. As to your statement "I was unaware then that you had
made any efforts to provide waivers of service on any of these
employees, and I now understand that no such efforts have ever been
made.  So this is clear, neither this Office nor those Division of
Insurance employees were ever asked, in any form, to waive service."
Before you call me a liar, I suggest you get your facts straight. I do
not know why the defendants did not inform you of the receipt of these
packages and waivers but they were definitely received by the Department
of Insurance.  The Green Cards addressed to Linda Ruthardt and the
Department of Insurance were also signed by Tyrone Nesmitt and you
acknowledged receipt of those.  The packages were all identical except
for the names on the Waivers of Service and they all included a stamped
self addressed envelope for the waivers to be returned to me.

Based on this I had every reason to assume that, should I try to have a
summons and complaint served by a deputy that the deputy might be evaded
or not let in to hand deliver the packages to the defendants.  It is my
understanding according to the instructions in the Step by Step guide
from the Springfield court that I could make service by having a
"disinterested" person who is over the age of eighteen deliver copies of
the Summons and Complaint to each of the defendants.  Since it was my
understanding that the lawsuit and summons must be delivered into the
HANDS of the defendants and I had reason to believe these defendants
might try to evade service since they had neither returned the Waivers
of Service, nor informed you of their existence, the server merely
stated that she had a delivery for these people in order to accomplish
her task.

Furthermore, although I recognize your desire to have me communicate
only with you, I do not believe it is illegal for a plaintiff to keep
the defendants in a lawsuit apprised of developments in the case.  I
hold these defendants personally responsible for dereliction of duty,
mail fraud, deception and lying.  They wrote deceptive letters
containing half-truths and false information about me in an attempt to
defend UNUM's indefensible position. Furthermore when Senator Brewer and
myself both informed them verbally and in writing that the information
contained in their letters was not true, they refused to investigate or
change the letter and engaged in further deceptions to protect UNUM
Insurance Company.

I find it extremely disturbing that the tax dollars of the Citizens of
the Commonwealth are going to attorneys to defend the very people who
were derelict in their duties to protect the citizens against this type
of fraud by insurance companies.  I only wish your office had been as
quick and vigilant in responding to my complaints of fraud and
harassment by UNUM Insurance Company as you were in responding to the
complaints of the defendants in this case. (The summons and complaints
were delivered yesterday.  Your letter to me arrived today.) I've been
complaining to the Attorney General's office with letters detailing the
fraud and harassment of this insurance company for over a year.

I am glad that you appreciated my attempt to inject some "humor" into
what is an appalling situation.  Unfortunately most of UNUM's victims
see nothing funny about the emotional, physical, and financial straits
they are put in by UNUM's ridiculous and implausible pretenses to deny
their claims and harass their doctors.  Furthermore as this lawsuit
progresses we will find out if the Massachusetts Department of Insurance
handled the other 30 of so complaints against UNUM in a similar fashion
to the way they handled mine, ignoring the law which requires an
investigation if there are more than 5 complaints.

I am more than willing to cooperate with the courts to get this action
in front of a jury as is my right under the 7th amendment of the US
Constitution.
I am doing my level best to follow both the Rules of Federal Procedure
and the Local Rules of the Court.

I also hope that your office will cooperate with me in this endeavor to
get at the truth.

Yours truly,



Judy Morris, MD

cc:  The Honorable Frank H. Freedman
     John C. Stuckenbruck, Deputy Clerk-in Charge
     Walter Marcinkus
     Solmaria Marquez
     Michael Goetz

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at: bhammel AT graham DOT main DOT nc DOT us





The URL for this document is:


http://graham.main.nc.us/~bhammel/INS/DOCS/2AAG121298.html


Created: December 18, 1998


Last Updated: May 28, 2000