I had to call Pat Peard, UNUM's attorney to give her notice before I
could file the above motion and Order. Apparently as soon as she heard
the message on her answering machine she sent the following letter. She
has not seen the contents of the Order and Motion yet, but I'm sure she
will continue to proclaim her innocense and good faith (without in
anyway, justifying them).
Judy E. Morris, MD
261 Bumstead Rd.
Monson, Massachusetts 01057
Re: Morris v. UNUM et al.
Dear Dr. Morris:
Thank you for you phone call of today. I understand that you intend to
file two motions: (1) a show cause motion; and (2) a motion to
disqualify me as attorney for UNUM. As I indicated to you in my
previous letter, UNUM is not willing to pay you benefits to which it
believes you are not entitled. In addition, you are correct in
concluding that we are not going to reach a compromise on your desire to
remove me from this case based on your misrepresentations regarding my
"behavior". I have ethically represented my clients and will continue
to do so.
Patricia A. Peard
cc: Ann Courtney, Esq.
Once again I'd like to know what dictionary she is using to define
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Created: February 3, 1999
Last Updated: May 28, 2000