NOVEMBER 2015 / $4

EARN MCLE CREDIT

THE MAGAZINE OF THE LOS ANGELES COUNTY BAR ASSOCIATION

Judge Michael J. Raphael (right),

Michael M. Farhang (center), and

Christopher A. Nowlin (left) contend that

properly focused discovery requests benefit

clients and courts

page 14

PLUS

JurorMisconductpage 21

PensionRecoupmentpage 11

Ethics ofAdvisingClientspage 60

TransactionalMediationpage 68

Just Discovery

InterpretingWillspage 26

SEMIANNUAL

GUIDE TO

EXPERT WITNESSES

14 Los Angeles Lawyer November 2015

HA

DI F

ARA

HA

NI

DISCOVERY DISPUTES and motion practiceconsume a significant portion of the docketsof California Superior Court judges. Giventhat the Code of Civil Procedure broadly autho-rizes discovery of nonprivileged, relevant mate-rial that is admissible or “reasonably calculatedto lead to the discovery of admissible evi-dence,”1 proper use of discovery is essentialto successfully advance a party’s position inlitigation. But indiscriminate use of discoveryas a litigation tactic is neither effective nordesirable. Overbroad discovery requests arelikely to meet judicial disapproval.2 On theother hand, California courts frown on overlynitpicky or nuisance objections that evaderequests seeking clearly relevant information.3

Either over-aggressive tactic is likely to resultin a dispute that may eventually require courtresolution. For many civil judges, a third or

more of the motions they hear pertain to dis-covery disputes, and plaintiffs’ and defenseattorneys also spend a significant amount oftheir time and their clients’ resources litigatingdiscovery disputes in order to further theirpositions.

These disputes are best avoided when pos-sible, and inordinate expenditures of time andmoney on thorny discovery disputes need notbe a part of every case. A large percentage ofdiscovery motions can be avoided with properinitial structuring of requests and responsesto make them more effective, combined withgood-faith efforts at informal dispute resolu-tion. Properly focused requests and responsescan help both sides succeed in identifying andobtaining the discovery they need to best rep-resent their clients. Meaningful and thoughtfuluse of the meet-and-confer process can help

JUSTD I S C O V E R Y

Properly focused discovery requests and responsesand good-faith use of the meet-and-confer processcan help save attorneys time and clients money

by Judge Michael J. Raphael, Michael M. Farhangand Christopher A. Nowlin

Michael J. Raphael is a judge on the Los Angeles Superior Court who presides over a civil calendar in theStanley Mosk Courthouse. Michael M. Farhang is a partner in the Los Angeles Office of Gibson, Dunn &Crutcher LLP, where he handles civil and criminal litigation matters. Christopher A. Nowlin is an associatein Gibson Dunn’s Los Angeles office, where he also handles litigation matters.

resolve disputes without result to motionpractice, which in turn will save attorney timeand client money and avoid the threat of dis-covery sanctions, which discovery rules pro-vide should be presumptively imposed againsta party that unsuccessfully makes or opposesa motion to compel absent a finding of sub-stantial justification or that sanctions wouldotherwise be unjust. Applying these principlescan help attorneys gain important credibilitywith the courts before which they appear.

One application of these principles is tonarrow the likelihood of disputes at the outsetby negotiating with opposing counsel to clar-ify the scope of discovery. Determining legit-imate discovery goals early and communi-cating with opposing counsel will increasethe efficiency of the discovery process. Oncea party’s discovery goals—i.e., what infor-mation will be needed to prove or defendthe case—have been analyzed and identified,attorneys should open the lines of commu-nication with opposing counsel. Communi -cation by a requesting party about the pur-poses and scope of the requests can help theparties define their expectations and startworking to resolve disputes before they arise.

One effective way to proceed is to nego-tiate a discovery protocol. Discovery is mostlikely to proceed smoothly, with the potentialfor disputes minimized, when the partieshave reached agreement on scope through aframework or protocol. Before initiating dis-cussions of a discovery framework withopposing counsel, attorneys can benefit fromfirst addressing discovery goals with theirclients and gaining familiarity with the uni-verse of potentially relevant documents, thelocations where those documents might befound, and the burden of searching them.Clients may be sensitive about producingparticular documents for a host of reasons.Attorneys should understand these sensitivitiesbefore beginning discussions with opposingcounsel so that they can negotiate a discoveryframework that best addresses their clients’concerns within the applicable rules.

There is no one-size-fits-all framework,but there are certain general characteristicscommon to effective discovery agreements.The first of these is a clear definition of thesources of documents to be searched. In theage of electronic discovery, clients (especiallycorporate clients) may maintain documentsin multiple forms of electronic media, rangingfrom e-mails to local files to centralized data-bases. And many clients continue to maintainhard-copy records. An effective discoveryprotocol should address which of thesesources will need to be searched in order toaccomplish the reasonable goals underlyingthe discovery requests. With respect to elec-tronically stored information (ESI), disputesfrequently arise over the manner in which

such data is produced. These disputes areavoidable and are far less likely to arise ifthe parties sit down with any available tech-nical support at the outset of discovery andreach agreement on discovery specificationsfor ESI. Additionally, agreeing on a frame-work for which custodians’ documents willbe searched and the date ranges for documentproductions can lessen the likelihood of futuredisputes arising.

Counsel should also work to reach agree-ment on the substantive scope of discovery.These disputes can present difficult dilemmasfor attorneys, but one of the best ways toprevent them is by addressing them beforediscovery even begins. Take as an example alandlord-tenant dispute involving allegationsthat the landlord breached housing standards.The tenant may seek discovery related to allof the buildings owned by the landlord toattempt to establish a pattern of misconduct.The landlord may object and argue that theonly relevant discovery is that concerningthe apartment building at issue or, even morenarrowly, the tenant’s particular unit. Becauseboth parties understand the risk that theirposition may not ultimately be accepted bythe court, a compromise agreement to meetsomewhere in the middle, e.g., discoveryrelating only to a limited number of otherproperties that are similarly situated, mightemerge as a more attractive solution aftersubstantial communication and a good-faitheffort to achieve a middle ground.

Experienced counsel may realize that thisresult is in fact a fair resolution and what acourt may end up requiring in any event. Byseriously debating and assessing the meritsof their positions at the outset of a case, andby working to find a middle ground if pos-sible, parties have the potential to forestalldisagreements from arising and bogging downthe discovery process.

Stated simply, opening the lines of com-munication with opposing counsel early isa basic but critical first step toward improv-ing effectiveness in the discovery process.Parties are less likely to enter into disputeswhen they are governed by a discovery frame-work in which they are mutually invested.Opposing counsel will be hard-pressed toargue that a position is unreasonable if theparties previously discussed and agreed tothat very position.

Exercise Restraint

A second principle is to be reasonable andexercise restraint in drafting discovery requestsand responses. Most attorneys have had theexperience of being served with voluminous,extremely broad, catchall discovery requestsor vague boilerplate objections unaccompa-nied by meaningful responses. Another wayto minimize the potential for unnecessary

motion practice is to use discerning judgmentin crafting discovery requests and responsesso that they target only what is necessary.

In serving discovery requests, counselshould tailor the requests to the informationthat they genuinely need to prove or defendtheir client’s case. Overly broad requests, orrequests that seek irrelevant information, serveonly the purpose of drawing legitimate objec-tions. Tailoring requests to more narrowlycover the critical subject matter will actuallyput more pressure on the responding party,which will have fewer grounds for objectionand may risk looking unreasonable if theparty resists a limited request. Moreover, clearand narrow requests better frame the issuesfor the court in the event of motion practice.As noted above, courts look unfavorably onexcessively overbroad discovery requests.4

Similarly, attorneys should be judiciousin crafting responses and objections to dis-covery requests. Quibbling with semanticsand advancing boilerplate objections withoutmeaningful responses are not conducive toreaching compromise on discovery issues.Nuisance objections will undermine the ap -pearance of a party’s good faith and willlikely draw court disapproval when used tofrustrate legitimate discovery requests.5 Mak -ing an unmeritorious objection or an evasiveresponse to discovery are considered misusesof the discovery process that can subject par-ties and attorneys to monetary sanctions.6

The responding party can enhance its credi-bility significantly if the court sees that it hascarefully considered its responses and objec-tions, tailored them to the particular requests,and made an effort to be forthcoming ratherthan evasive.

When facing requests that are overly broadbut seek some relevant information, attorneysare advised to provide at least some mean-ingful responses in addition to articulatingtheir legitimate objections. For example, if adefendant in a personal injury action seeks10 years of medical records from a plaintiff,an overbreadth objection may be warranted,depending on the circumstances, but a con-structive response could include the produc-tion of clearly relevant records from a nar-rower period of time.

A third principle is to always engage ina meaningful meet-and-confer process beforebringing discovery disputes to the court. TheCode of Civil Procedure requires that partiesengage in a meet-and-confer process beforethe filing of most discovery motions inCalifornia civil courts. Motions to compelfurther responses to document requests, inter-rogatories, and requests for admissions allmust be accompanied by a declaration statingfacts showing a “reasonable and good faithattempt” to resolve informally the issuespresented by the motion.7 The process can

16 Los Angeles Lawyer November 2015

be conducted in writing, over the phone, orin person.8

The purpose of the meet-and-confer re -quirement is to “encourage the parties towork out their differences informally so asto avoid the necessity for a formal order.”9

The process is designed to narrow discoverydisputes as much as possible before seekingjudicial intervention. A failure to make rea-sonable, good-faith efforts at an informalresolution may be considered a misuse of thediscovery process,10 and the court may imposemonetary sanctions, including attorney’s fees,on the offending party or attorney regardlessof the outcome of the motion.11 While fewpublished California authorities elaborate onthe “reasonable and good faith” meet-and-confer requirement, those that do providesound guidance for how to approach informalresolution. Attorneys should heed the lessonsof these cases, which can help avoid costlymotion practice and the imposition of sanc-tions by the court.

Simply going through the motions of themeet-and-confer process without a sincereeffort to seek a real resolution of the disputedissues may not satisfy the statutory require-ment. Townsend v. Superior Court,12 forexample, illustrates this point. In that case,a plaintiff refused to answer questions duringher deposition.13 This spurred a heated back-and-forth exchange between the attorneysduring the deposition about the propriety ofher refusal to answer.14 The plaintiff remainedsteadfast in her refusal, and the defendantsmoved to compel.15 In opposing the motion,the plaintiff argued that the defendants hadfailed to sufficiently meet and confer.16 Thetrial court rejected this argument, holdingthat the back-and-forth discussion at thedeposition sufficed.17 The trial court grantedthe defendants’ motion to compel.18

The court of appeal reversed the trial court,holding that the limited back-and-forth at thedeposition did not suffice for the meet-and-confer requirement.19 In an often-cited opinion,Justice Steven J. Stone explained that the pur-pose of the meet-and-confer requirement isto “lessen the burden on the court and reducethe unnecessary expenditure of resources bylitigants through promotion of informal, extra-judicial resolution of discovery disputes.”20

The process requires that the parties “presentto each other the merits of their respectivepositions with the same candor, specificity,and support during informal negotiations asduring the briefing of discovery motions.”21

The parties must make a serious effort at infor-mal resolution, which “requires that counselattempt to talk over the matter, compare theirviews, consult, and deliberate.”22 The defen-dants’ failure to adequately meet and conferled the court of appeal to reverse the trialcourt’s order and direct the trial court to deny

the motion to compel.23

Further, a lack of diligence in initiating themeet-and-confer process may undermine anattorney’s claim that the process was undertakenin good faith. In Obregon v. Superior Court,24

the court applied Townsend in the context ofa failure to adequately meet and confer beforemoving to compel further responses to inter-rogatories. Notably, Obregon ties the reason-

ableness of a party’s meet-and-confer effortsto both the reasonableness of the underlyingdiscovery requests and the speed with whichthe propounding party pursues informal reso-lution after receiving objections to its requests.

The plaintiff in Obregon served very broadinterrogatories on the defendant.25 After thedefendant responded, the plaintiff waited fiveweeks, or until just 13 days were left withinthe 45-day period to move to compel, beforesending a letter to the defendant requestingfurther responses.26 The defendant respondedwith a letter that the plaintiff received onlyone day before the motion deadline and thatreiterated the same objections.27 The plaintifffiled a motion to compel.28 The defendantopposed the motion on the basis that theplaintiff had failed to adequately meet andconfer.29 The trial court agreed with the defen-dant, denying the plaintiff’s motion and impos-ing sanctions on the plaintiff for failing toadequately meet and confer.30

The court of appeal affirmed the trialcourt’s ruling that the plaintiff failed to ade-quately meet and confer. The court reasonedthat the “overbreadth of the requests” wasrelevant to the question of whether the partiesmet and conferred in good faith, observingthat “[h]ere plaintiff propounded grossly

overbroad interrogatories” and, after receiv-ing defendant’s objections, “simply sent asingle brief letter, late in the relevant timeperiod…mak[ing] no effort to explain whyinterrogatories of such breadth are properin this case, an omission that reasonably sug-gests lack of a proper discovery objective.”31

While every case presents its own facts,the lesson from Townsend and Obregon is

that counsel should make every effort tomake the meet-and-confer process a mean-ingful opportunity for both parties to resolvetheir dispute in the way it should be resolved,rather than a hollow and perfunctory exercisenecessary before filing a motion.

A constructive meet-and-confer processis especially important given the statutoryrequirement that a court shall impose mon-etary sanctions on a party that unsuccessfullymakes or opposes a motion to compel unlessthe losing party shows that it acted with sub-stantial justification or that the impositionof sanctions would be unjust.32 In otherwords, a party that loses on a motion tocompel may find itself facing an argumentfrom the other side that monetary sanctionsare appropriate absent an exception.33 Thisstringent statutory scheme further highlightsthe importance of making serious efforts atinformal resolution and avoiding unnecessarymotion practice on discovery issues.

A recent premises liability case in JudgeRaphael’s court serves as an example of whyit is important to ensure that objections todiscovery requests are well-taken. In thatcase, the defendant, a movie theater, hadmade reasonable relevancy objections to aseries of broad requests for factual informa-

Los Angeles Lawyer November 2015 17

tion about prior similar slip-and-fall incidentson the property. At an informal discoveryconference, the parties agreed to narrow therequest to a limited time period (two years)for a particular area of the theater (an areanear the concession stand, where the plaintiff’sincident occurred). Yet, following the con-ference, the defendant disclosed only thedates of three prior similar incidents andrefused to disclose facts about the incidents,though such facts had been requested. Upongranting the plaintiff’s motion to compel theinformation about the incidents, the courtalso imposed sanctions at the plaintiff’srequest to compensate her for litigating themotion to compel. While the defendant’s ini-tial objection was justified, the objection andfailure to respond adequately to the narrowedrequest was without substantial justification.

How can attorneys avoid the prospect ofa meet-and-confer process in which counselare simply going through the motions ratherthan actively seeking to narrow or resolvedisputes? First, a party that identifies a dis-covery issue should not delay in conferringwith opposing counsel. As a formal matter,the meet-and-confer process does not auto-matically extend the 45-day period for bring-ing a motion to compel, so promptly startingthe process can ensure that a meaningfulprocess can occur before a motion is due. Asa practical matter, a delay in initiating dis-covery discussions may show a lack of goodfaith.34 Importantly, a delay in a meaningfulmeet-and-confer attempt can have the effectof locking the parties into their positions,should they begin preparing for motion prac-tice before efforts at informal resolution begin.

Second, the meet-and-confer process maystand a better chance of succeeding in somecases if the meeting takes place in person.While the rules permit the conference to beaccomplished through letters, in practicethese letters tend to contain more than a littleposturing and advocacy, particularly giventhe probability that they will end up asexhibits to a motion to compel. Courts mayappreciate seeing a meet-and-confer processthat includes more than a simple exchangeof letters. And, as in Townsend, a judge mayconclude that such advocacy and argumentdo not suffice.35 When an in-person meetingtakes place, it is best if an attorney withauthority to resolve the discovery disputescan be in attendance.36

Third, both sides should approach themeet-and-confer process prepared to com-promise to whatever extent they can withouttruly compromising their legitimate discoveryinterests. A requesting party should considerreasonable restrictions on its requests, whilea responding party should contemplate howit can expand on what it offers in responseto requests. While resolution may not always

be possible, willingness to compromise willshow the court that the parties have mademeaningful attempts to narrow the points ofdispute. And, as in Obregon, unreasonablediscovery requests (and responses for thatmatter) may discredit a party and suggest tothe court that it did not take the meet-and-confer process seriously.

A fourth principle is to participate in aninformal discovery conference or other infor-mal avenues for resolving discovery disputes.Negotiations are not always successful, andeven meet-and-confer efforts undertaken ingood faith will not resolve every discoverydispute. In such cases, the parties may stillhave other options before resorting to motionpractice. The Personal Injury Courts in theLos Angeles County Superior Court, forexample, require that the parties engage inan Informal Discovery Conference (IDC)prior to filing motions to compel furtherresponses to discovery requests. The purposeof the IDC “is to assist the parties to resolveand/or narrow the scope of discovery dis-putes.”37 Critically, judges in the PersonalInjury Courts “have found that, in nearlyevery case, the parties amicably resolve dis-putes with the assistance of the Court.”38

This high rate of success is certainly attrib-utable in part to the presence of the judge,which encourages the parties to earnestlycome to the negotiating table, lessen theirposturing, and be more reasonable in theirpositions. The IDCs also provide the partieswith insight into which way a judge is leaningon a particular issue, which might indicatethat motion practice is not a wise choice.

Importantly, the scheduling of an IDCdoes not extend the deadline for filing amotion to compel. Because of this, partiesshould try to schedule an IDC as soon as adispute is identified, as the IDC “may avoidthe necessity of a motion or reduce its scope.”39

In most cases, both parties would be bestserved by entering into a stipulated extensionof the 45-day motion to compel deadline.This will allow them to enter the requiredIDC without having invested too much timein preparing their motions, which could fur-ther entrench them in their positions.

Opportunities to receive informal judicialassistance in resolving discovery disputes arenot limited to the Personal Injury Courts.Many Los Angeles County Superior Courtjudges make themselves available, eitherthrough telephonic or in-person conferences,to address and attempt to resolve discoverydisputes so to avoid unnecessary motion prac-tice. These informal conferences provide thesame benefits as the IDCs in the PersonalInjury Courts. They are an effective way ofbringing attorneys to the negotiating tableand persuading them to moderate their posi-tions. Attorneys can take a number of steps

to determine if a particular civil judge allowsfor these informal discovery conferences.These include 1) checking the court’s websiteand looking under “courtroom information”for the specific judge, 2) raising the matterwith the judge at the case management con-ference, to hear directly from the judge whathe or she believes should be done with a dis-covery dispute, and 3) contacting the judicialassistant (i.e., courtroom clerk) to inquirewhether the judge would be amenable to aninformal conference. Notably, some judgesallow the parties to enter into a discoveryresolution stipulation that governs discoverydisputes. These stipulations are “intended toprovide a fast and informal resolution of dis-covery issues through limited paperwork andan informal conference with the Court toaid in the resolution of the issues.”40

California civil judges also have the statu-tory authority to “appoint a referee to hearand determine any and all discovery motionsand disputes relevant to discovery in theaction and to report findings and make arecommendation thereon.”41 Often, the activeinvolvement of a court-appointed referee,who may have more time than a judge tofocus on resolving discovery disputes, canhelp facilitate the meet-and-confer processand increase the likelihood of informal res-olution. Because of this, civil litigants maywant to explore the prospect of requesting adiscovery referee at the outset of a case.

Motion practice on discovery issues shouldbe a last resort for civil litigants in Californiastate court. While some intractable issues can-not be resolved absent court intervention, alarge portion of discovery disputes can beavoided or resolved informally if approachedconstructively. Both practitioners and theirclients benefit from making meaningful effortsto informally resolve discovery disputes. At -torneys can be more effective at getting thediscovery they need without resorting to costlyand unnecessary motion practice. And makinggood-faith efforts to resolve disputes will pro-tect counsel from the risk of sanctions forabuse of the discovery process. Moreover, aneffective meet-and-confer process and judiciousstructuring of discovery requests and responsescan help attorneys improve their credibilitywith the court. The court will appreciate nothaving its busy docket consumed with dis-covery motions that could have been avoidedif the attorneys had en gaged in a constructivedialogue. Given the serious demands and bur-dens placed on today’s state court system, areduction in the number of discovery motionscan free up time for courts to address othercritical merits-related issues. This benefits alllitigants. n

1 CODE CIV. PROC. §2017.010.2 See, e.g., Obregon v. Superior Court, 67 Cal. App.

18 Los Angeles Lawyer November 2015

http://www.aldavlaw.com

4th 424, 431 (1998) (“When discovery requests aregrossly overbroad on their face, and hence do notappear reasonably related to a legitimate discoveryneed, a reasonable inference can be drawn of an intentto harass and improperly burden.”).3 See Clement v. Alegre, 177 Cal. App. 4th 1277,1285-93 (2009); see also Standon Co., Inc. v. SuperiorCourt, 225 Cal. App. 3d 898, 901 (1990).4 See Obregon, 67 Cal. App. 4th at 431.5 See Clement, 177 Cal. App. 4th at 1285-93; seealso Standon Co., 225 Cal. App. 3d at 901.6 CODE CIV. PROC. §§2023.010(e), (f), 2023.030; seealso Clement, 177 Cal. App. 4th at 1292-93 (affirmingtrial court’s award of sanctions against party thatprovided “evasive” discovery responses).7 See CODE CIV. PROC. §§2016.040, 2031.310(b)(2)(motion to compel further responses to requests fordocument production), 2030.300(b) (motion to compelfurther responses to interrogatories), 2033.290(b)(motion to compel further responses to requests foradmissions).8 CODE CIV. PROC. §2023.010(i).9 Stewart v. Colonial W. Agency, Inc., 87 Cal. App.4th 1006, 1016 (2001) (quotations omitted).10 CODE CIV. PROC. §2023.010(i).11 Id. CODE CIV. PROC. §2023.020.12 Townsend v. Superior Court, 61 Cal. App. 4th1431 (1998).13 Id. at 1434.14 Id. at 1434, 1436-37.15 Id. at 1434.16 Id.17 Id.18 Id.19 Id. at 1439.20 Id. at 1435.21 Id. (quoting Nevada Power Co. v. Monsanto Co.,151 F.R.D. 118, 120 (D. Nev. 1993)).22 Id. at 1438-39.23 Id. at 1439.24 Obregon v. Superior Court, 67 Cal. App. 4th 424(1998).25 Id. at 428.26 Id.27 Id.28 Id.29 Id.30 Id.31 Id. at 431-32.32 CODE CIV. PROC. §§2023.030(a), 2031.320(b)(motion to compel further responses to requests forproduction), 2030.300(d) (motion to compel furtherresponses to interrogatories), 2033.290(d) (motionto compel further responses to requests for admis-sions).33 Mattco Forge, Inc. v. Arthur Young & Co., 223Cal. App. 3d 1429, 1441 (1990).34 Volkswagenwerk Aktiengesellschaft v. SuperiorCourt, 122 Cal. App. 3d 326, 333-34 (1981); see alsoObregon, 67 Cal. App. 4th at 432.35 See also Clement v. Alegre, 177 Cal. App. 4th1277, 1294 (2009).36 Volkswagenwerk, 122 Cal. App. 3d at 333-34 (rea-soning that an attorney’s delegation of the meet-and-confer process to a paralegal without authority toresolve the dispute was unreasonable).37 Los Angeles County Superior Court Fourth AmendedGeneral Order Re Personal Injury Court Procedures¶11, available at http://www.lacourt.org/division/civil/pdf/4thAmendedPIProcedures_012615.pdf.38 Id.39 Id. at ¶12.40 Los Angeles County Superior Court Form CIV-036 (Discovery Resolution Stipulation).41 CODE CIV. PROC. §639(a)(5).

20 Los Angeles Lawyer November 2015

Paying Highest Referral Fees (Per State Bar Rules)

Honored to receive regular employment referrals fromover 100 of Californiaʼs fi nest attorneys

Main offi ce located in Los Angeles and nearby offi ces in Pasadena, Orange County, Inland Empire & San Diego

EMPLOYMENT LAW REFERRALS

Stephen Danz, Senior Partner

Stephen Danz & Associates 877.789.9707

11661 San Vicente Boulevard, Suite 500, Los Angeles, CA 90049

Want to retire? Want to plan for your life after law!

See Ed Poll’s websitewww.lawbiz.com for the tools

you need to make a transition.

Want to buy a practice? Ed can help!

Call today 800.837.5880

Law Firms 4 Sale

EXPERT WITNESS � CLAIMS CONSULTANT

Contact Gene Evans at E. L. Evans AssociatesTel 310.559.4005 • Fax 310.559.4236 • E-mail elevans66@yahoo.com

9854 NATIONAL BOULEVARD, SUITE #225, LOS ANGELES CA 90034

EXPERT IN GOOD FAITH/BAD FAITH, STANDARDS AND PRACTICESand standard in the industry. Specialties in property/casualty construction defect,fire/water, uninsured/un der insured motorist, warehouse and cargo claims. Failure to defend and/or indemnify. Litigation support, case review and evaluation claim consultation, coverage review and valuations. Appraisal, Arbitration and ClaimsRep. at MSC & MMC.

— Over 45 Years Experience as a Claims Adjuster —LICENSED IN THREE STATES AND QUALIFIED IN STATE AND FEDERAL COURTS

EXPERIENCE—

INTEGRITY—

HONESTY