[December 9, 1998]

Commonwealth of Massachusetts
Office of the Attorney General
One Ashburton Place
Boston, MA  01057

Dear Dr. Morris,

I understand that today some kind of purportedly humorous attempt at
service of process was made on the following persons at the Division of
Insurance: Walter Marcincus, Solmaria Marquez, and Michael Goetz.  This
attempt took the form of someone entering the offices of the Division of
Insurance under false pretenses and leaving holiday-wriapped packages
containing what was apparently supposed to be service of process at or
near these employees work stations.  Please be advised that this Office
will appear in this action for these individuals, in addition to the
parties identified in my letters to you of 23 and 24 November, despite
the fact that this clumsy essay at service is of course not effective.
Even if this had been valid service, please be advised that neither any
defendant nor this Office will pay for this disturbing stunt.  As I
advised you in my letter of 24 November, 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.

In light of this Office's representations of the defendants identified
in previous and in this correspondence, it is not necessary that you
provide copies of filings to any of them.  Indeed, I ask that you have
no direct communication with any of these defendants about the subject
matter of this litigation because these parties are represented.  Your
filing and communications should be sent to me directly.  (My fax number
is 784-1244).  The defendants which this Office represents are: Senator
Linda J. Melconian, the Office of  Consumer Affairs and Business
Regulation, the Attorney General (L. Scott Harshbarger), The Divisioin
of Insurance, Linda Ruthardt as Commissioner for the Division of
Insurance, Walter Marcinkus, Solmaria Marquez, Michael Goetz, and the
Commonwealth of Massachusetts.

Thank you for your anticipated cooperation.

Very truly yours,

H. Gregory Williams
Assistant Attorney General
Director of Defensive Litigation
Western Massachusetts Division

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Created: December 18, 1998


Last Updated: May 28, 2000