Judy Morris, MD
261 Bumstead Rd.
Monson, MA 01057
December 14, 1998
The Honorable Judge Frank H. Freedman
United States District Court
District of Massachusetts
Federal Building and Courthouse
1550 Main Street
Springfield, MA 01103
RE: Civil Action CA98-30204-FHF
This is a very difficult letter for me to write. I'm sure it is out of
the ordinary and I will get in trouble for it. As best I can tell I'm
not doing anything illegal.
Your honor, I have brought the above lawsuit in an effort to get at the
truth in a court of law as was the intention of our founding fathers. I
was told there were Rules both of Federal Court and Local Court and that
if I followed those rules, I stood a good chance of achieving the
justice that was the intention of our lawmakers.
However, as I read Local Rule 7.1(f) "Decision of Motion without
Hearing. Motions that are not set down for a hearing as provided in
subsection (e) will be decided on the papers submitted after the
opposition to the motion has been filed, or, if no opposition is filed,
after the time for filing an opposition has elapsed."
Already you have ruled favorably on two motions filed by defendants'
lawyers to allow unlicensed lawyers leave to practice in this state in
this case. While I understand these motions are customarily approved, I
do believe that I should at least have my oppositions considered. In
the first instance I filed the opposition immediately although your
decision came so quickly I'm not sure you saw it. In the case of
attorneys Kayatta and Sanchez, the Motion was received December 9 and
approved by you on December 10th. I was preparing to file an opposition
to this motion within the week.
These motions were not requested as an Ex Parte motion, nor was the
requisite conference between parties conducted. Since I would more than
likely not have access to out of state attorneys, allowing the
defendants to use them puts me at a distinct disadvantage. These
attorneys' qualifications have not been scrutinized by the Massachusetts
Board of Bar Overseers. We have only their word that they are
reputable, ethical and knowledgeable and as I have pointed out in my
oppositions to these motions, the have already proven they are not
familiar with the Local Rules and are not following them.
I tried to use lawyers to try this case. I have had bad advice or been
abandoned by three attorneys. I am still actively trying to find law
firms to file class actions on the part of other claimants who don't
have the courage and educational and emotional resources that I have to
try it on my own. Still the emotional impact of this on me is
incredible. My family and doctors admonish me frequently for neglecting
my own needs in an attempt to right a social wrong.
Your honor, I am asking you as a learned judge, a pillar of the
community and as a human being to grant me the deference the rules
If you have read my lawsuit you would see that according to UNUM, the
fact that I can drive my car proves I am capable of being a full time ER
By that same logic, should you ever become disabled by a chronic pain
condition, immune disorder, traumatic brain injury or other "invisible"
disability, UNUM would deem you able to fulfill the duties of a judge if
you were capable of sitting in a chair, regardless of your true
condition or what your doctors and common sense would dictate.
Furthermore, Assistant Attorney General H. Gregory Williams, has called
me a liar when in fact he didn't even check the facts proving that it
was not I who is lying.
I know that a lot of what goes on in the courts has little to do with
justice. I am hoping the people who tell me these things are wrong
because if this is so than the courts have betrayed the founding fathers
and the citizens of the country and themselves.
I am beseeching you to search your conscience, your motives, your sense
of fairness and justice, why you became an attorney in the first place
and remember that the actions you take in my case and others like it
will affect us all, including you and members of your own family. If
society selectively enforces certain rules on certain groups but not on
others, rules that lawmakers have carefully laid out to apply to all;
if the laws and rules are to be only selectively and arbitrarily
enforced, then what is the purpose of having law and rules?
At some point in the near future my opponents are going to try to
overwhelm me with work. Despite my symptoms, and the many extra hours I
will need to spend in bed and the many extra pain relievers I will have
to take in order to be able to function, I will do my best to keep up
with them. This does not however prove that I can return to my job as
an Emergency Room Doctor full time. Based on all of my doctors
opinions, the extensive research conducted by the Centers for Disease
Control and the National Institutes of Health, to even attempt this
would be dangerous to myself and my patients.
And anything less than 80% does not absolve UNUM of their responsibility
to pay my claims.
Enclosed please find:
1) Opposition to Motion to admit Attorneys Kayatta and Sanchez Pro Hac
2) A letter I received from H. Gregory Williams, Assistant Attorney
General, calling me a liar because I had process served on 3 defendants
who did not waive service.
3) My response to his letter proving that it is not I who is lying.
I am not sure if letters of this type need to be sent to all defendants,
so I will err on the side of doing it.
Judy Morris, MD
CERTIFICATE OF SERVICE
I hereby certify that a true copy of the above document was served
by United States Postal Mail, postage prepaid upon the US District Court
of the District of Massachusetts and upon all defendants in Morris v.
UNUM, et al. on _14_ day of December, 1998.
Judy Morris, MD
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Created: December 17, 1998
Last Updated: May 28, 2000