See Also the ADDENDUM of 02/04/99 to this motion.




UNITED STATES FEDERAL COURT
    DISTRICT OF MASSACHUSETTS

JUDY E. MORRIS, MD   )
      )
   Plaintiff  ) Civil Action No. CA 98-30204 FHF
      )
v.      )
      )
UNUM CORPORATION OF AMERICA,  )
 et al.    )
   Defendants

     ORDER TO SHOW CAUSE TO ENJOIN UNUM INSURANCE TO
SPECIFIC PERFORMANCE OF CONTRACTS AND TEMPORARY
RESTRAINING ORDER PURSUANT TO FED.RUL. CIV. P. RULE 65
CERTIFICATION OF PERSONAL CONSULTATION


CERTIFICATION OF PERSONAL CONSULTATION

Plaintiff hereby certifies that her attempt to confer with UNUM's
counsel in Good Faith, pursuant to Local Court Rule 7.1(a)(2) took the
form of the following:
Attachment A:  Plaintiff sent Attorney Patricia Peard notice of the
filing of this motion, certified return receipt, and requested Ms. Peard
to call plaintiff to confer.
Attachment B: Ms. Peard wrote plaintiff a letter accusing plaintiff of
not acting in Good Faith and stating her position that there is
essentially nothing to confer about.
Attachment C:  Plaintiff's written response to Ms. Peard.  Any further
effort on the part of plaintiff to confer with Ms. Peard is obviously
futile.  On January 28, 1999, Plaintiff left a message on Ms. Peard's
answering machine giving her Notice that plaintiff would be filing this
Order to Show Cause and the accompanying Motion to Disqualify Opposing
Counsel.  Plaintiff did not attempt to actually confer with Ms. Peard
because 1) plaintiff has been attempting to confer with UNUM, Ms.
Peard's client numerous times since March 1997, with no reciprocal
effort on UNUM's part, 2) Although plaintiff attempted to trust Ms.
Peard, as detailed herein, this trust was unfounded, 3) the requirement
for plaintiff to make continued attempts to negotiate with her
tormentors is causing plaintiff great emotional distress.
ORDER TO SHOW CAUSE TO ENJOIN UNUM INSURANCE TO
     SPECIFIC PERFORMANCE OF CONTRACTS AND TEMPORARY
RESTRAINING ORDER PURSUANT TO FED.RUL. CIV. P. RULE 65

Now comes plaintiff, Judy Morris, MD, asking this court why order should
not be entered enjoining UNUM Insurance Company
to pay plaintiff monthly disability benefits per her contracts.

A. Parties
    Plaintiff, Judy E. Morris, MD, a citizen of the State of
Massachusetts has filed a lawsuit against multiple defendants including
UNUM Corporation in U.S. District Court, District of Massachusetts.
    Defendant, UNUM Corporation, UNUM Company, UNUM Life Insurance
Company or any name they might choose to call themselves, hereafter
referred to as "UNUM", a corporation based in Portland, Maine and
conducting business in 49 states and Puerto Rico. 2211 Congress St.,
Portland, ME 04122.  Defendant herein is UNUM Life Insurance Company of
America, a foreign corporation and which has registered with the
Massachusetts Secretary of State as a foreign corporation doing business
within the Commonwealth.
B. Jurisdiction:
    This court has jurisdiction over this action pursuant to diversity
of citizenship, 28 U.S.C. 1332, in that plaintiff is a citizen of the
State of Massachusetts, defendant UNUM is a citizen of and has principal
place of business in another state, the amount in controversy exceeds
the sum of $75,000, exclusive of interest and costs.  Alternatively this
court has jurisdiction over this action because it is part of a larger
Federal lawsuit pursuant to the charge of violating Federal Racketeering
Statutes (RICO), 18 USC 1961-1968, therefore this court has jurisdiction
in that the claim in this motion is part of the original case or
controversy under Article 3 of the United States Constitution.
    Defendant UNUM is subject to personal jurisdiction within this
judicial district, and therefore resides in this judicial district and
this is a proper venue for this Civil Action pursuant to 28 U.S.C 1391.
Defendant UNUM was, at all times, or presumed to be, registered with the
Massachusetts Secretary of State as a foreign corporation doing business
within the Commonwealth as an insurer within the meaning of M.G.L. c.
176D.
C. Facts
    1.  Plaintiff has two contracts of disability insurance from UNUM,
an individual policy Number LAD106032, Claim CLA963248 and a group
policy through her employer, Number 00052614-0001, Claim 0098463761.
Attachments D & E.
    2.  Plaintiff is disabled from performing the material and
substantial duties of her occupation as an Emergency Doctor on a regular
basis according to the terms of both insurance policies.
Plaintiff's Chronic Fatigue Syndrome prevents her from "engaging in her
regular occupation" as accommodations cannot be made for her disability.
"An insured suffers total disability when he is prevented from
performing each and every duty though he may be able to perform, perhaps
with peril to himself, occasional acts relating to his vocation, but not
constituting a substantial part of any 'daily duty.'" McGroll v.
Equitable Life Assurance Soc'y of the U.S., 292 N.Y.419, 426 55 N.E. 2d
483, 487 (1944)(citing Fitzgerald v. Globe Ind. Co., 258 P. 458 (Cal.
Ct. App 1927); Harrison v Provident Life & Accident Ins. Co. 70 S.W. 2d
24 (Tenn.1934). "Insured is "wholly unable to perform any work" within
total and permanent disability provisions of life insurance policy, if
he can do no work without seriously endangering his health or risking
his life." M.G.L. 175  24, Note 2.  Plaintiff is totally disabled from
her occupation as an Emergency Physician based on this definition.  Not
only would she be endangered but her patients as well.  This fact is
supported by plaintiff's internist Dr. McIlvaine, Attachment F and
Affidavit, plaintiff's second opinion, Dr. Glew, Attachment G,
plaintiff's third opinion, Dr. Nancy Klimas, who is a nationally
recognized expert in the research, diagnosis and treatment of Chronic
Fatigue Syndrome, Attachment H:1-3.  Plaintiff has extensive medical
documentation dating back to 1995 with laboratory confirmation of
plaintiff's immunologic condition and a sleep disorder, Attachment
H:4-16.  Plaintiff's group insurance agent Jack Taylor, individual
insurance agent Betty Rae Poppo, and plaintiff's former employer,
Harrington Memorial Hospital, have all stated verbally or in writing
that they feel this claim should be paid.  Plaintiff's employer has
declared plaintiff "totally disabled" in Court documents and plaintiff's
boss has stated that her position cannot be modified to accommodate her
disability Attachment I.  Agent Jack Taylor wrote UNUM an extensively
detailed letter to the effect that he saw no contractual or reasonable
excuse for UNUM to deny this claim, Attachment J.  Betty Rae Poppo's
declarations were orally to plaintiff and in the form of a letter
offering plaintiff assistance (although Mrs. Poppo never followed
through on this letter when plaintiff requested that assistance, and
Mrs. Poppo also subsequently admitted in person to plaintiff that her
own claim (Mrs. Poppo's) for Short Term Disability Benefits had been
denied by UNUM.) Attachment K.  Plaintiff has complied with all
reasonable requests from UNUM in a timely fashion. (Footnote 1).
3.  Plaintiff is not suffering from a psychiatric or psychological
problem as the primary cause of her disability.  This fact is supported
by plaintiff's psychiatrist, Dr. Joel Klass, Attachment L, and her
internist Dr. McIlvaine, previous Attachment F.  Furthermore Brian Dorsk
v UNUM, No 97-97-P-C(Me.D.Apr.10, 1998) states that the doctrine of
contra preferentum dictates that if the "plaintiff has a disorder with
an organic cause and mental manifestations," mental illness limitations
are ambiguous and must be strictly "construing the terms against the
insurer."
    4.  UNUM has consistently and fraudulently denied plaintiff's
disability benefits under both policies, except for
a $4000 payment made on her group policy under the pretense that
plaintiff was "depressed" for 4 months.
----------
Footnote 1: Prior to the institution of plaintiff's Racketeering Lawsuit
against these aforementioned insurance agents and her employer,
plaintiff had asked them repeatedly to write more letters or otherwise
assist her in encouraging UNUM to honor these claims; claims they all
insisted should be honored.  Despite offers of assistance, no further
aid was given to plaintiff.  Now, these three defendants are offering
plaintiff affidavits in support of her position only if she will drop
her racketeering charges against them.
-----------------
    5.  Plaintiff was offered a "lowball" settlement at a meeting in
Hollywood, Florida between plaintiff and UNUM Field Investigator Steve
Harris, at the instruction of UNUM Group Adjuster Frankie Puthoff, on or
about April 16, 1997 in the amount of $86,710.37.  Considering that
plaintiff's disabling condition is permanent and incurable by current
medical standards, her benefits to age 65 would have been in excess of
$3,500,000.  Attachment M. "Under life policy providing for benefits for
total and 'permanent' disability as result of bodily injury or disease,
a disability is 'permanent' if it will continue for an indefinite period
which is likely never to end, even though recovery at some remote or
unknown time is possible" M.G.L.   24, Note 3.
    6.  Defendant UNUM has made no meaningful attempt or effort to
rehabilitate, negotiate or deal in Good Faith with plaintiff.
Footnote 2.
---------
Footnote 2: Definition of Good Faith, Black's Law Dictionary, Abridged
Sixth Edition. "Good faith. Good faith is an intangible and abstract
quality with no technical meaning or statutory definition, and it
encompasses, among other things, an honest belief, the absence of malice
and the absence of design to defraud or to see an unconscionable
advantage, and an individual's personal good faith is concept of his own
mind and inner spirit and, may not conclusively be determined by his
protestations alone.  Honesty of intention, and freedom from knowledge
of circumstances which ought to put the holder upon inquiry.  An honest
intention to abstain from taking any unconscientious advantage of
another, even through technicalities of law, together with absence of
all information, notice, or benefits or belief of facts which render
transaction unconscientious.  In common usage this term is ordinarily
used to describe that state of mind denoting honesty of purpose, freedom
from intention to defraud, and generally speaking, means being faithful
to one's duty or obligation."

    7.  Defendant UNUM has engaged in a variety of unethical and illegal
activities forcing plaintiff to file a lawsuit. UNUM's investigation of
plaintiff's disability claims consisted of
invasions of privacy, unwarranted and sloppy surveillance, violations of
Federal Credit laws, and the investigation was neither thorough, prompt,
nor objective and in fact was biased only towards finding or inventing a
pretense to deny plaintiff's claims.  Despite the extensive use of
private investigators and a large amount of money spent "investigating"
this claim, UNUM did not interview plaintiff's boss, her co-workers, nor
anyone who knew her.  In fact, during the one-on-one meeting plaintiff
had with UNUM Field Investigator Steve Harris on February 25, 1997 in
Nashville, plaintiff's significant other, Michael Dalterio, who was
present, tried to tell Mr. Harris of his observations regarding
plaintiff's illness and behavior.  Mr. Harris abruptly cut off and
terminated the interview at this point.  (Plaintiff has a tape recording
of this conversation, taken with Mr. Harris's permission.)  Despite the
obvious disagreement between UNUM and plaintiff's treating physicians,
UNUM never once had plaintiff go for an Independent Medical Examination
or even had her chart reviewed by an Independent examiner.  No doubt,
UNUM will now ask for this as a delaying tactic and an attempt to find
or pay for another pretense to further deny these claims.  UNUM engaged
in "lowballing," "stonewalling," "rubberballing," deceptions, attempted
to influence plaintiff's doctors and prejudice them against her, delays,
threats and consistently failed to honor the law and the doctrine of
contra preferentum. UNUM has failed to come forward with any credible
evidence to raise a genuine issue of material fact that plaintiff is not
totally disabled as defined under the terms of her insurance contracts.
    8.  UNUM and Plaintiff's claims adjuster Frankie Puthoff come to
this litigation with "unclean hands." UNUM's reputation and tactics have
been noted by other judges in other courts.  Judge Spencer Letts
described Frankie Puthoff's testimony in the case of John Dishman v
UNUM, Case No. 96-0015JSL, 1997 U.S. Dist. LEXIS 22676, 98 Daily Journal
DAR 10340; 21 E.B.C. 2941, as showing a "lack of credibility."
Attachment N-8.  Judge     Jed S. Rakoff, Paciello v. First UNUM, 96
Civ. 3206 JSR, 1996, has called into question that he believes UNUM is
not a "good corporate citizen."  Judge Steve D. Sheldon, Russell v. UNUM
Life, CV 95-12521, Dec. 8, 1998, has appointed a "Special Master" to
investigate UNUM due to his suspicions that UNUM may have given
"willful, intentional or misleading responses to discovery requests or
interrogatories".  John O'Connell, Ph.D, CPCU, in a sworn affidavit in
Steve Russell's lawsuit against UNUM, has stated under oath that among
other things "UNUM established a policy geared toward resisting and
denying as many claims as possible in order to improve its profitability
and eliminate its operating losses," and that UNUM's conduct "would be
characterized as emanating from an'evil mind.'"Attachment O.
D. Causes of Action
    9. This Order to Show Cause is meant only to address the Breach of
Contract Cause of Action in plaintiff's complaint.
E. Request for Order to Show Cause and Temporary Restraining Order.
    10. Plaintiff will suffer irreparable injury if the defendant

is not enjoined from further wrongful denial and breach of

contract during the pendancy of this lawsuit and if defendant is

not ordered to pay plaintiff her disability benefits and fulfill

the terms of her contracts.

    11. The irreparable harm threatened to occur to plaintiff if

this injunction is denied will take the form of the following:

In the current legal system, the ability of a disabled
plaintiff to get justice through the courts depends primarily upon their
ability to physically, mentally, emotionally, and financially withstand
prolonged delays and expenses in order to get a judgment on the merits
of the case.  As the saying goes "Justice Delayed is Justice Denied."
If plaintiff loses any one of these four components at any
time during this litigation, she will be permanently and forever denied
equitable relief even if the court would have ultimately decided in her
favor, had she been able to continue.  She may also suffer permanent and
irremediable harm as detailed below.
     Physically:  Plaintiff is burdened with limited physical and mental
energy and endurance.  A considerable amount of this limited energy and
endurance is being used in the furtherance of her attempt to get Due
Process under the law and the Constitution.  Many UNUM claimants, even
those with attorneys, have complained that filing a claim for disability
benefits under a UNUM policy is a full-time job.  Plaintiff may be
working "full time" at this "job" but it is within her capabilities as
the hours are variable, she can work from home and take frequent naps,
and the exposure to immunologic and physical stresses is minimal as her
work is largely sedentary.  Despite this she has episodes occurring
approximately every 4 to 6 weeks where she must spend an inordinate
amount of time resting or in bed, her mental function deteriorates, and
she experiences many of the other symptoms of Chronic Fatigue Syndrome
(chills, sore throats, headaches, muscles aches, weakness, and increased
requirements for pain medication).  However, as the litigation
continues, plaintiff may be subjected to increased physical demands,
such as court appearances, taking depositions, traveling to get
evidence, depositions and witnesses, and time constraints requiring
prolonged hours to meet deadlines which will exacerbate her symptoms
further.  A severe relapse of this type could result in significant
compromise of plaintiff's legal case by missed deadlines, sheer
exhaustion, or mistakes.
     Also in these states of severe exhaustion plaintiff's judgment and
awareness are compromised when she performs ordinary tasks such as
driving and cooking which could, and in fact, have resulted in serious
accidents and near accidents in the past.
    Mentally:  With adequate rest, plaintiff's mental function may be
maintained.  Her short term memory, even on a good day is not normal,
and she frequently forgets things she meant to do or say, unless she has
specific reminders.  In the writing of lawsuits, complaints, and
motions, this is largely not a problem, because plaintiff is not
required to make irreversible life and death decisions, while distracted
and exhausted, and she has time (usually) to recheck her work several
times and have others do this also.  Plaintiff's mental limitations may
become more obvious during oral arguments, telephone conversations,
conferences, negotiations, and trial appearances, particularly if she is
unable to get adequate rest.  These problems usually consist of short
term memory problems, mixing up words and phrases, saying one thing
while meaning another, word finding difficulty, irritability and
emotional lability and other problems which may compromise her case if
her mental condition deteriorates, which it may, due to the
unpredictable nature of her illness and this litigation.
     Emotionally:  Plaintiff, by self knowledge, and the opinions of her
psychiatrist and psychologist, and as noted by UNUM's Dr. Pringle, due
to her philosophical outlook and secondary effects of her illness, is
prone to suicidal ideation when under great stress.  In the current
situation, plaintiff is very careful to monitor her emotions and take
appropriate action in the way of extra rest, and consultation with those
in her support system, when she feels her emotional function
deteriorating.  However, as noted by plaintiff's psychologist Dr.
Kebrdle and UNUM's Dr. Pringle, if forced to return to full time
Emergency Room work, she would be likely to become suicidal again.
Attachment P. Suicide is by nature an impulsive and irreversible act.
Plaintiff did not return to work as an ER doctor because of the truth of
what Dr. Pringle reported Dr. Kebrdle had said in that statement.
Because, other than this lawsuit, plaintiff currently has minimal
stresses in her life, and she is able to control these symptoms.
However, with her limited resources being rapidly depleted and facing
the increased stresses of bankruptcy or returning to part time work
while simultaneously fighting this lawsuit, plaintiff's compensatory
mechanisms could be overcome with suicide as the result.  The stress of
litigation, and/or other unpredictable factors (accidents, sickness or
death of loved ones or other tragedy, stress on personal relationships)
could result in increased stresses and precipitate a suicidal crisis.
Plaintiff has already developed an abiding paranoia and distrust of
corporations, the government and the legal system and this is likely to
increase with time.  At times she fears someone may try to kill her.
     Financially:  Plaintiff has currently cashed in her retirement
funds and investments in order to pay her living expenses and the
expenses of this litigation.  She has cashed in her savings accounts,
IRA's and Mutual funds, suffering tax liabilities, penalties, and loss
of dividends and investment income as a result.  She has incurred extra
expenses attempting to get her claim paid, investigating and suing UNUM
(over $6000 in office and postal expenses so far, not including phone
bills). Plaintiff is currently driving 2 very old vehicles, both of
which need constant repairs.  If both fail she will not have
transportation to the post office and courthouse as she lives in a rural
area, much less the grocery store, and she will be deprived of any
chance of due process.  She has continuing living expenses of mortgage,
homeowner's insurance, car insurance, taxes, electric, phone, food,
snowplowing (a necessity at plaintiff's home), propane, repair bills,
and a few luxuries like Cable TV and occasional new clothes and travel
to visit her mother or father.  Plaintiff has given up health insurance
since she is no longer eligible under any group plan.
Had her benefits not been wrongly denied she would have been eligible to
continue her group insurance benefits through her employer.  She now
must pay for her own health expenses and prescriptions and is limited to
the extent that she can try new or experimental treatments for CFS
because of their expense.
Plaintiff may be forced to relinquish her medical licenses in
Massachusetts and Connecticut since these cost $250 and $450 dollars to
renew, and plaintiff also doesn't feel she can afford the costs of the
Continuing Education Courses (or the time and energy to take them)
required to maintain licensure. Plaintiff has already gone on inactive
status in the American Academy of Family Physicians to reduce her dues
from $350 to $50 per year.
Plaintiff may be forced to declare bankruptcy or take out a loan
(although that might be difficult with no job and no collateral)
in order to continue this litigation and pay her living expenses at the
same time. Up until this point of dealing with UNUM plaintiff has had a
perfect credit record and never been in debt.  There is also the
question of whether the Y2K problem will cause plaintiff further
expenses or give the defendants further excuses to delay the trial.
     Now the obvious question would be why doesn't plaintiff just hire a
lawyer to do the work for her.  Plaintiff has for over a year attempted
to get legal representation.  She has been represented for brief periods
by 3 attorneys who proved less than satisfactory.  Other arrangements
would require plaintiff to pay considerable hourly rates up front, or
high retainers ($10,000 in one case).  But, even with an attorney on
contingency, she would still have other costs and a lot of work
associated with the litigation.  By knowledge (after talking extensively
with other insurance claimants who are represented by attorneys) and
belief, plaintiff feels that hiring an attorney to represent her would
serve neither her needs nor the needs of justice in this case.
    12. From Dishman v. UNUM, US States District Court for the Central
District of California, Case No. 96-0015, 1997 U.S. Dist. LEXIS 22676;
98 Daily Journal DAR 10340; 21 E.B.C. 2941.  "Most persons in Dishman's
position would not have had the legal sophistication or financial
ability to wait for the bad faith denial to be redressed by a court.
Their only option would have been to settle on terms very favorable to
the insurance company."  "UNUM's bad faith acts placed pressure on the
Dishmans because they were deprived of monthly income which they needed
to live.  A lump sum benefit after a lawsuit, even with interest and
free from legal expense, did nothing to alleviate the pressure upon them
at the time the claim was denied and during the entire course of the
litigation."  "Dishman suffered irremediable harm as a result of the
termination of benefit payments to him.  He has been forced to sell
stocks and make distributions from his IRA in order to pay living
expenses.  As a consequence, he has incurred taxable income which might
have been deferred or avoided".  Mrs. Dishman was required to return to
full time employment.  The purpose of disability payments is to provide a
disabled individual with periodic income with which to pay living
expenses.  The receipt of a lump sum at the conclusion of an appeal of
this case will not compensate Mr. Dishman for the loss of periodic
income."  Without this order being granted plaintiff, unlike Mr. Dishman
who was able to get to court, may well become another casualty in UNUM's
war of attrition.
    13.  There is substantial likelihood that plaintiff will prevail on
the merits because of those "stubborn facts."  UNUM's case and it's
continued denial of plaintiff's claim is based on innuendo, defamation
and the hearsay statements of UNUM's Dr. Pringle and Dr. Mirkin as to
what plaintiff's doctors said over the telephone.  UNUM's arguments
refuting plaintiff's disability are untenable, implausible and
ludicrous.  UNUM's "lowball" settlement offer is Prima Facia evidence of
Bad Faith.  There are many legal precedents to support plaintiff's proof
of disability based on the evidence she has already presented and a
minimum of common sense, including the evidence presented at the time
the claims were originally denied and the fact that if UNUM needed more
proof plaintiff had made every attempt to ascertain what they might want
prior to this time.  Attachment Q.
14.  The threatened harm to plaintiff, as stated above, clearly
outweighs the harm a preliminary injunction would inflict on defendant.
In fact in 1997, UNUM had Revenues of $4.1 billion and a Net Income of
$370.3 million.  Fairness would clearly dictate that UNUM could "loan"
plaintiff her benefits on the remote risk that she would lose her case
far more easily than plaintiff can afford to "loan" UNUM her benefits
pending the outcome of a lawsuit.  Good Faith would dictate that UNUM
should not only pay claimant's benefits while litigation proceeds but
pay for her legal expenses as well.  If plaintiff is deprived of Due
Process by the above duresses, her interest free "loan" to UNUM will
turn into a permanent robbery (or at the very least "Unjust Enrichment"
at plaintiff's expense).
15.  Issuance of this Order is in the public interest because it clearly
would a) enforce the law that states that ambiguities in insurance
contracts must be found in favor of the insured, "Insurance contracts
are liberally construed in favor of the insured." United States Fidelity
& Guar. Co. v Annunziota, 67 N.Y. 2d 229,232, 492 N.E. 2d 1206, 1207,
501 N.Y.S. 2d 790, 791 (1986), "ambiguities in standard-form contracts
supplied by one party are generally construed against that party" Sea
Westchester Rosco Co. v New England Reinsurance Corp. 818 F.2d 2,3(2d
Cir. 1987), M.G.L. 175  2 Note 5 "Where there is ambiguity in the terms
of an insurance contract, the ambiguity must be interpreted strictly
against the insurer." Ciaramitaro v Saskatchewan Government Ins. Office
(D.C.1956)144 F. Supp. 237, b) help somewhat in leveling the playing
field, at least financially, c) deter powerful and wealthy insurance
companies from denying legitimate claims on fraudulent pretenses and
then using the legal system for extortion.
    16.  Plaintiff asks the court to Order UNUM to honor said contracts
immediately and set its application for a for hearing, if the court
requires it, at the earliest possible time and, after hearing the
application, issue a preliminary injunction against the defendant UNUM.
F.  Request for a Permanent Injunction
    17.  Plaintiff asks the court to set its application for injunctive
relief for a full trial on the issues in this application and, after the
trial, to issue a permanent injunction against the defendant.
G.  Prayer
    18. For these reasons, plaintiff asks that the court Order UNUM
immediately to enforce the contracts, enter judgment for plaintiff for
the amount of her back benefits in the amount of $287,261, Attachment R,
as of January 1, 1999, absent interest and Cost of Living increases,
order UNUM to continue paying plaintiff her monthly benefits until a
trial court resolves the issues, and grant any other relief it deems
appropriate, such as requiring UNUM to pay plaintiff's legal costs of
this litigation that plaintiff was maliciously forced into by UNUM's
behavior.
     19. Signed under the penalties of perjury this 28th day of January,
1999.
Judy E. Morris, MD
       PRO SE


      CERTIFICATE OF SERVICE
    I hereby certify that a true copy of the above document was
delivered in person January 29thh, 1999 to US District Court, District
of Massachusetts, Springfield and served by United States Postal Mail,
postage prepaid upon the following attorneys representing all defendants
in Morris v. UNUM, et al. Mailed on January 29th, 1999.



       Judy E. Morris, MD
       PRO SE

Patricia A. Peard, Esq.   representing "UNUM" Katherine A. Robertson,
Esq.    "UNUM's" local counsel
William J. Kayatta, Esq.   representing Robert Crispin
H. Gregory Williams    representing State of Mass.,
     Harshbarger, Melconian, DOI,
  Ruthardt, Goetz, Marcinkus,
   Marquez
Tracy L. Devlin, Esq.   representing IFB and Michael
E. Michael Sloman, Esq.   Gray
Thomas H. Hayman, Esq.   representing Betty Rae Poppo
Robert Pierce, Esq.    representing Harrington and
   Mangion
Christopher N. Jones   Co-Counsel for Transunion
Carolyn G. Sullivan    representing Jack Taylor





See Also the ADDENDUM of 02/04/99 to this motion.


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The URL for this document is:
http://graham.main.nc.us/~bhammel/INS/DOCS/order012899.html
Created: February 3, 1999
Last Updated: May 28, 2000