The response to UNUM's letter of 11/16/98

Judy Morris, MD
							261 Bumstead Rd.
							Monson, MA  01057
							(413) 267-3606

Patricia A. Peard					November 21, 1998
Bernstein, Shur, Sawyer $ Nelson
100 Middle St. #9
Portland, ME  04101-4166

Dear Ms. Peard,

You have set the tone for our interactions by refusing to allow me the
simple courtesy of having an accurate record of any telephone conversations
or interactions.  I am under no illusions, as you have seen from my lawsuit,
about the type of people I am dealing with in this matter.

It is apparently the intention of UNUM and its attorneys to do everything
possible to avoid having an accurate record that can be presented to a judge
and jury in a court of law.  I have no problem with my words being recorded,
or in fact, my actions being recorded as UNUM has so graciously already done
for me.  My doctors were willing to allow me to record telephone conversations
with them.  ONLY UNUM and its representatives refuse to have their words
recorded. I have not been given any reason for this.  I can only assume it
is so you will have the opportunity to play "he said, she said" when we get
to court as you tried to do with my doctors when they innocently engaged in
unrecorded conversations with Dr. Pringle and Dr. Mirkin.

I consider my goal in this endeavor to get this case in front of a judge
and jury.  The way I see it, your job will be to do anything and everything
to delay that or prevent me from introducing evidence and witnesses.  And
of course I expect further harassment, unnecessary paperwork, and intrusions
into my privacy that have nothing to do with the issues at hand and refusal
by UNUM and defendants to produce policy manuals and other information that
would further support my allegations.  Let's see if my prediction comes true.

As far as you being counsel for UNUM defendants and vendors, until I hear
this from EACH defendant, I have no way of knowing if they even know you
exist.  Maybe some of them have or wish to have their own lawyers.  Maybe
some of them would wish to deal with me directly.  Until I hear otherwise
from each and every defendant themselves, I will continue to direct business
directly to the people I have the dispute with.

It will unnecessarily complicate matters if we cannot communicate by phone
but a written record will provide much better proof anyway of your actions,
inactions and deceptions.

Meanwhile as you hopefully already know, I am in touch with the media,
networking with plaintiff's lawyers throughout the country, and have a
website that will detail everything that transpires during the course
of this litigation (including this letter).

We continue to be dismayed by the efforts of UNUM and other insurers to
heap emotional and financial pain and distress on their own policyholders
after they are obviously already dealing with some devastating medical
problems, implying and accusing them of crimes, engaging in deceptions
and cruel attempts to disrupt their relationships with their treating
physicians, giving false "advice," even trying to convince the public of
the great service you are doing and that anyone you choose not to pay must
be a fraud.  Look, I'm not disputing that you do pay some claims, that
HMO's do provide some services that people might not otherwise be able
to afford.  But we don't reward a child molester for all the other
children he was NICE to and gave candy.  We don't reward a murderer
because 90% of the time he was a decent person.  We don't reward robbers
because they DIDN'T rob 90% of the time.  We punish people for CRIMES
they commit.

You and UNUM are breaking promises and contracts by fraud, deceit,
harassment and attempting (and sometimes succeeding) in driving
claimants to suicide.

Maybe you don't agree with my approach to this problem.  That's fine.
I believe in dealing with people honestly and forthrightly.  That may
defy some political and social traditions but it has been very effective
in righting social wrongs in the past.

So continue to play your games.  Eventually we will get to the point where a
judge and jury can decide who's been lying.

Alternatively, I would suggest that you read the section of the lawsuit
that describes the damages I am demanding, particularly those sections
that describe my desire to have UNUM treat its other claimants fairly and
justly in their time of need. If you and UNUM start treating these people
fairly and justly it might mitigate some of the damages a jury will award.

Very sincerely,

Judy Morris, MD

Certificate of Service:
I hereby certify that on November 21, 1998, I mailed a true and correct
copy of the foregoing document postage prepaid to the following people.
(my signature)_____________

cc: UNUM's Ann Courtney 
    All defendants in Morris v. UNUM et al, Docket No. CA-98-30204-FHF
    US District Court, District of Massachusetts, Springfield, MA
    Non-Defendant Board Members of UNUM

Addendum: If I do not receive back the signed waivers of service enclosed
with the complaints by November 27,1998 I will be forced to have sheriffs
or deputies serve defendants with the summons and complaint.  I am prepared
to do this.  You and defendants can avoid the appearance of further bad faith
and attempts to delay the proceedings by simply returning these forms that
the court requires.  You will also avoid the costs of service by simply
returning these forms.

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Created: November 21, 1998
Last Updated: May 28, 2000