Date: Thu, 24 Sep 1998 05:47:49 -0400
From: judy morris 

Federal Rules of Civil Procedure 
(b) Discovery Scope.  Parties may obtain discovery regarding any matter,
not privileged, which is relevant to the subject matter involved in the
pending action, whether it relates to the claim or defense of the party
seeking discovery or to the claim or defense of any other party,
including the existence, description, nature, custody, condition and
location of any books, documents, or other tangible things and the
identity and location of persons having knowledge of any discoverable
matter. it is not ground for objection that the information sought will
be inadmissible at the trial if the information sought appears
reasonably calculated to lead to the discovery of admissible evidence.

The frequency or extent of use of the dicovery methods set forth in
subdivision (a) shall be limited by the court if it determines that; (i)
the discovery sought is  unreasonably cumulative or duplicative, or is
obtainable from some other source that is more convenient, less
burdensome, or less expensive (if UNUM asks me to provide the names of
other claimants - they already have that information in their
possession) (ii) the party seeking discovery has had ample opportunity
by discovery in the action to obtain the information sought; or (iii)
the discovery is unduly burdensome or expensive, taking into account the
needs of the case, the amount in controversy, limitations on the
parties' resources, and the importance of the issues at stake in the

This source also reassured me that at least up until 10 years ago, the
Mafia REFUSED to do business with insurance companies.  There are
reasons why this fellow would know. Hopefully, the Mafia is still keeping
their distance from the insurance companies, although there are rumors
that even that has changed.  Mostly, I understand the Mob is still in
the garbage hauling business.

On a more disturbing but UNVERIFIED note, reports are starting to come in
that UNUM's books are so altered that they have insufficient money to
cover their policies, and what money there is, of course, after the outward
expenses are covered, is funneled off to Swiss Bank accounts and estates
on the Riviera.

To those of you who are getting paid.  I just want you to know that with
OR WITHOUT my efforts, if the situation is this bad, UNUM's house of cards
did not have long to stand anyway.  Many lawyers across the country are
putting together coalitions to fight UNUM.  I may be the most vocal one,
but please, if the worst happens try to place the blame where it belongs -
ALLOWED THIS TO GO ON - and not on me.


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Created: September 24, 1998
Last Updated: May 28, 2000