[ Pobierz całość w formacie PDF ]
. How many policies are out there? I've actually asked this question indiscovery, and am still waiting for a reply. Just under a hundred thousand.If you figure a claim rate of ten percent,that's ten thousand claims a year, about the average for the industry.Let'ssay they deny, just for the hell of it, half of the claims.Down to fivethousand.The average claim is ten thousand dollars.Five thousand times tenthousand is fifty million bucks.And let's say they spend ten million, just afigure from the air, to settle the few lawsuits that pop up.They clear fortymillion with their little plot, then maybe the next year they start paying thePage 205 ABC Amber Palm Converter, http://www.processtext.com/abcpalm.htmllegitimate claims again.Skip a year, go back to the denial routine.Cook upanother scheme.They make so damned much money they can afford to screwanybody. 159I stare at him for a long time, then ask, Can you prove this? Nope.Just a hunch.It's probably impossible to prove because it's soincriminating.This company does some incredibly stupid things, but I doubt ifthey're dumb enough to put some-thing this bad in writing. I start to mention the Stupid Letter, but decide against it.He's on a roll.He'll win every battle of one-upsman-ship. Are you active in any trial lawyer groups? lie asks. No.I just started practicing a few months ago. I'm pretty active.There's a loose network of us lawyers who enjoy suinginsurance compa-nies for bad faith.We keep in touch, you know.Lots of gossip.I'm hearingGreat Benefit this and Great Benefit that.I think they've denied too manyclaims.Everybody's sorta waiting for the first big trial to expose them.Ahuge verdict will start the stampede. I'm not sure about the verdict, but I can guarantee there will be a trial. He says he might call his buddies, work the network, interface, gather thegossip, see what's coming down around the country.And he might just be inMemphis in February to watch the trial.One big verdict, he says again, willburst the dam.I SPEND HALF of the next day backtracking through Jackson's file, then thankhim and leave.He insists that I keep in touch.He has a hunch that a lot of lawyers will bewatching our trial.Why does this scare me?I drive to Memphis in twelve hours.As I unload the Volvo behind Miss Birdie'sdark house, a light snow begins to fall.Tomorrow is the new year.FortyTHE PRETRIAL CONFERENCE IS HELD IN the middle of January in Judge Kipler'scourtroom.He arranges us around the defense table, and stations his bailiff at the doorto keep wandering lawyers out.He sits at one end, without his robe, hissecretary on one side, his court reporter on the other.I'm to his right, withmy back to the courtroom, and across the table is the entire defense team.It's the first time I've seen Drummond since Kord's deposition on December 12,and it's a struggle to be civil.Every time I pick up my office phone I cansee this well-dressed, perfectly groomed and highly respected thug listeningto my conversation.Both sides have submitted proposed pretrial orders, and we'll work out thekinks today.The final order will serve as a blueprint for the trial.Kipler was only slightly surprised when I showed him the manuals I borrowedfrom CooperJackson.He's carefully compared them to the manuals submitted to me byDrummond.Accord-ing to His Honor, I am not required to notify Drummond that I know now they'vewithheld documents.I'm perfectly within the rules to wait until the trial,then spring this on Great Benefit in front of the jury.It should be devastating.I'll yank down their pants before the jury and watchthem run for cover.We get to the witnesses.I've listed the names of just about everybodyconnected with the case.Page 206 ABC Amber Palm Converter, http://www.processtext.com/abcpalm.html Jackie Lemancyzk no longer works for my client, Drummond says. Do you know where she is? Kipler asks me. No, This is true.I've made a hundred phone calls to the Cleveland area andhave not found a trace of Jackie Lemancyzk.I even convinced Butch to try andtrack her by phone, and he had the same luck. Do you? he asks Drummond. No. So she's a maybe. That's correct. Drummond and T.Pierce Morehouse think this is funny.They exchange frustratedgrins.It won't be so cute if we're able to find her and get her to testify.This, however, is a long shot. What about Bobby Ott? Kipler asks. Another maybe, I say.Both sides can list the people they reasonably expectto call at trial.Ott looks doubtful, but if he turns up I want the right to call him as awitness.Again, I've hadButch asking around for Bobby Ott.160We discuss experts.I have only two, Dr
[ Pobierz całość w formacie PDF ]