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| frisky effete philosopher-king parlour | 05/25/18 |
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| frisky effete philosopher-king parlour | 05/25/18 |
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| vigorous wrinkle digit ratio | 05/25/18 |
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| Lilac french locale place of business | 05/26/18 |
| Lilac french locale place of business | 05/26/18 |
| frisky effete philosopher-king parlour | 05/25/18 |
| Provocative Copper House Pervert | 05/25/18 |
| floppy jet travel guidebook menage | 05/26/18 |
| Racy ratface home | 05/25/18 |
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| frisky effete philosopher-king parlour | 05/25/18 |
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| peach resort | 05/25/18 |
| frisky effete philosopher-king parlour | 05/25/18 |
| vigorous wrinkle digit ratio | 05/25/18 |
| burgundy stage | 05/25/18 |
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| Wine multi-colored hospital old irish cottage | 05/25/18 |
| Rebellious incel round eye | 05/25/18 |
| Stimulating Tank | 05/25/18 |
| frisky effete philosopher-king parlour | 05/25/18 |
| vigorous wrinkle digit ratio | 05/25/18 |
| umber doctorate | 05/25/18 |
| Cerise theater stage | 05/25/18 |
| frisky effete philosopher-king parlour | 05/25/18 |
| 180 coral stage | 05/25/18 |
| Racy ratface home | 05/25/18 |
| Wine multi-colored hospital old irish cottage | 05/25/18 |
| vigorous wrinkle digit ratio | 05/25/18 |
| Cerise theater stage | 05/25/18 |
| Confused jade school cafeteria coldplay fan | 05/25/18 |
| Chartreuse national pisswyrm | 05/25/18 |
| Cerise theater stage | 05/27/18 |
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| frisky effete philosopher-king parlour | 05/25/18 |
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Poast new message in this thread
Date: May 25th, 2018 4:24 PM Author: frisky effete philosopher-king parlour Steve,
I received your faxed letter today dated May 25 (erroneously dated May 14), 2018. In your letter you claim to be unable to accept or reject our 998 offer at this time. You further state that the 998 offer is premature. This is not correct.
State Farm has sufficient information to make a determination at this time. Ms. REDACTED has nearly $25,000 in current Howell meds and also has recommendations for significant future treatment, including cervical and lumbar epidural injections. Moreover, her business suffered tremendously and we have already provided documentation to substantiate her loss of earnings claim claim. You received Ms. REDACTED's medication special nearly a year ago (July 14, 2017) and this case has been in litigation since August 29, 2017. This means that you have had nearly eight months to subpoena any records you needed to substantiate Ms. REDACTED's injury and economic loss claims. Moreover, you also have our written discovery responses. It is our understanding from that your insured's policy limits are $50,000. Our client's lost earnings claim alone is significantly higher than your policy. A deposition is not necessary for State Farm to determine this claim is worth more than it's policy limits.
For those reasons, we will not provide any extension of this 998. In fact, if our 998 expires, our next demand will be for $200,000 and we will seek contribution from your insured. Please inform your insured (as is your obligation) that we have offered to settle the claim against them within their policy limits and that if that offer is not accepted, we will seek personal contribution from them. Also be advised that when we depose your insured. we will ask them if they were made aware of our 998 offer and we will inform them that we are now seeking personal contribution against them.
I look forward to your response by our 998 deadline of June 7.
Let me know if you have any questions. |
Date: May 25th, 2018 4:24 PM Author: frisky effete philosopher-king parlour He called me an hour later (a couple minutes ago) and told me he is trying to get policy limits now. (http://www.autoadmit.com/thread.php?thread_id=3986533&forum_id=2#36127711) |
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Date: May 25th, 2018 4:25 PM Author: 180 coral stage (http://www.autoadmit.com/thread.php?thread_id=3986533&forum_id=2#36127718) |
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Date: May 25th, 2018 4:26 PM Author: Racy ratface home why did you send the 998 demand so long after the suit was filed? is that typical? (http://www.autoadmit.com/thread.php?thread_id=3986533&forum_id=2#36127721) |
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Date: May 25th, 2018 4:26 PM Author: frisky effete philosopher-king parlour Wanted them to have our discovery responses first so the 998 was more solid. (http://www.autoadmit.com/thread.php?thread_id=3986533&forum_id=2#36127728) |
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Date: May 25th, 2018 4:29 PM Author: Racy ratface home damn. so you can't lock in the 998 demand at the beginning of every lawsuit. that would be sweet! (http://www.autoadmit.com/thread.php?thread_id=3986533&forum_id=2#36127749) |
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Date: May 25th, 2018 4:30 PM Author: frisky effete philosopher-king parlour You can but there was no rush and it is more likely to be upheld if you do written discovery. (http://www.autoadmit.com/thread.php?thread_id=3986533&forum_id=2#36127754) |
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Date: May 25th, 2018 4:31 PM Author: Cerise theater stage can you only make one 998 demand? ie, are you screwed if u made your 998 demand early on and they had a reasonable basis to reject it? can you just make another one later in the case? (http://www.autoadmit.com/thread.php?thread_id=3986533&forum_id=2#36127760) |
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Date: May 25th, 2018 4:34 PM Author: frisky effete philosopher-king parlour You can send an unlimited amount. (http://www.autoadmit.com/thread.php?thread_id=3986533&forum_id=2#36127782) |
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Date: May 25th, 2018 7:18 PM Author: Lilac french locale place of business Does California have some sort of good faith or knowledge limitation on them? (http://www.autoadmit.com/thread.php?thread_id=3986533&forum_id=2#36128712) |
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Date: May 25th, 2018 4:29 PM Author: Cerise theater stage 180 work. keep us poasted. thankj (http://www.autoadmit.com/thread.php?thread_id=3986533&forum_id=2#36127746) |
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Date: May 25th, 2018 4:33 PM Author: abusive adventurous indirect expression Good. tell him to get a move on. (http://www.autoadmit.com/thread.php?thread_id=3986533&forum_id=2#36127773) |
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Date: May 26th, 2018 2:28 PM Author: floppy jet travel guidebook menage 180 (http://www.autoadmit.com/thread.php?thread_id=3986533&forum_id=2#36131970) |
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Date: May 25th, 2018 4:25 PM Author: Stirring Flushed Love Of Her Life there's an embarrassing repeated word in there man, you need to punish kenny (http://www.autoadmit.com/thread.php?thread_id=3986533&forum_id=2#36127720) |
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Date: May 25th, 2018 4:27 PM Author: frisky effete philosopher-king parlour This is shitlaw, not biglaw.
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Date: May 25th, 2018 4:30 PM Author: umber doctorate 180 regardless (http://www.autoadmit.com/thread.php?thread_id=3986533&forum_id=2#36127753) |
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Date: May 25th, 2018 5:00 PM Author: Slate ticket booth His point stands. You need to punish kenny (http://www.autoadmit.com/thread.php?thread_id=3986533&forum_id=2#36127923) |
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Date: May 26th, 2018 6:01 PM Author: sable concupiscible useless brakes box office (http://www.autoadmit.com/thread.php?thread_id=3986533&forum_id=2#36132948) |
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Date: May 25th, 2018 4:29 PM Author: umber doctorate Also an it's (http://www.autoadmit.com/thread.php?thread_id=3986533&forum_id=2#36127748) |
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Date: May 25th, 2018 4:30 PM Author: plum comical pit skinny woman Also, a period is used instead of a comma (http://www.autoadmit.com/thread.php?thread_id=3986533&forum_id=2#36127752) |
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Date: May 25th, 2018 4:31 PM Author: frisky effete philosopher-king parlour Dude, I pump out like 100 e-mails a day making threats. I don't really proof read (which is funny because I was on law review). (http://www.autoadmit.com/thread.php?thread_id=3986533&forum_id=2#36127758) |
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Date: May 25th, 2018 4:32 PM Author: Cerise theater stage poast more like this. these are great (http://www.autoadmit.com/thread.php?thread_id=3986533&forum_id=2#36127762) |
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Date: May 25th, 2018 4:37 PM Author: umber doctorate these things only matter to fat, balding partners with rosacea running a kike casino nightmare machine. you've got the best job on this board and the comma checkers are trying to show off what they're learning in biglaw (http://www.autoadmit.com/thread.php?thread_id=3986533&forum_id=2#36127796) |
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Date: May 25th, 2018 4:59 PM Author: Rusted Irradiated Cuck (http://www.autoadmit.com/thread.php?thread_id=3986533&forum_id=2#36127907) |
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Date: May 25th, 2018 5:17 PM Author: Impertinent Arousing Half-breed Business Firm (http://www.autoadmit.com/thread.php?thread_id=3986533&forum_id=2#36128023) |
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Date: May 25th, 2018 4:41 PM Author: plum comical pit skinny woman I’m just messing with you. Im an inhousemo, biglaw refugee, and i dont GAF about typos either. (http://www.autoadmit.com/thread.php?thread_id=3986533&forum_id=2#36127808) |
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Date: May 25th, 2018 4:59 PM Author: Olive Alcoholic Hall 180 (http://www.autoadmit.com/thread.php?thread_id=3986533&forum_id=2#36127912) |
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Date: May 25th, 2018 5:42 PM Author: Confused jade school cafeteria coldplay fan (http://www.autoadmit.com/thread.php?thread_id=3986533&forum_id=2#36128196) |
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Date: May 25th, 2018 4:33 PM Author: Racy ratface home he writes these emails on his phone directly in the gmail app. while multitasking and managing an office. (http://www.autoadmit.com/thread.php?thread_id=3986533&forum_id=2#36127770) |
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Date: May 25th, 2018 4:34 PM Author: Cerise theater stage and poasting (http://www.autoadmit.com/thread.php?thread_id=3986533&forum_id=2#36127783) |
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Date: May 25th, 2018 5:43 PM Author: Confused jade school cafeteria coldplay fan (http://www.autoadmit.com/thread.php?thread_id=3986533&forum_id=2#36128199) |
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Date: May 25th, 2018 4:26 PM Author: indigo rigor you had to file a lawsuit over a 50K policy limits claim? jesus. (http://www.autoadmit.com/thread.php?thread_id=3986533&forum_id=2#36127722) |
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Date: May 25th, 2018 4:27 PM Author: frisky effete philosopher-king parlour It happens some times. If you don't file on these smaller cases you lose credibility on everything. I file at least 1 lawsuit a week. (http://www.autoadmit.com/thread.php?thread_id=3986533&forum_id=2#36127734) |
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Date: May 25th, 2018 4:37 PM Author: abusive adventurous indirect expression (http://www.autoadmit.com/thread.php?thread_id=3986533&forum_id=2#36127794) |
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Date: May 25th, 2018 5:01 PM Author: Olive Alcoholic Hall (http://www.autoadmit.com/thread.php?thread_id=3986533&forum_id=2#36127930) |
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Date: May 25th, 2018 5:13 PM Author: Contagious pocket flask 1 lawsuit a week sounds like a shitload. Maybe you've got a lot more support staff than me. My goal is to file 2 lawsuits against each major insurance carrier every year. And it doesn't look like I'm gonna hit that target this year, except for GEICO. (http://www.autoadmit.com/thread.php?thread_id=3986533&forum_id=2#36128003) |
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Date: May 25th, 2018 5:20 PM Author: Wine multi-colored hospital old irish cottage Dude, you need to study Cali’s model. He will literally tell you everything on the phone. He’s going to end up with affiliate firms in all 50 states. (http://www.autoadmit.com/thread.php?thread_id=3986533&forum_id=2#36128044) |
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Date: May 25th, 2018 7:20 PM Author: frisky effete philosopher-king parlour Did we chat on the phone? (http://www.autoadmit.com/thread.php?thread_id=3986533&forum_id=2#36128729) |
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Date: May 25th, 2018 4:26 PM Author: Greedy crackhouse kitty cat scary email (http://www.autoadmit.com/thread.php?thread_id=3986533&forum_id=2#36127725) |
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Date: May 25th, 2018 4:28 PM Author: Racy ratface home Cr (http://www.autoadmit.com/thread.php?thread_id=3986533&forum_id=2#36127742) |
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Date: May 25th, 2018 4:29 PM Author: Provocative Copper House Pervert http://www.smwb.com/ccp-998-offer-a-settlement-offer-with-strings-attached
wholly shit I've been hearing about these "998 letters" and never knew what they were. Not a tortmo, but is this just a CA thing? |
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Date: May 25th, 2018 4:31 PM Author: vigorous wrinkle digit ratio kinda. CA is unique in that plaintiffs can send them as well as defendants. Under federal law (and most states) only defendants can send them (http://www.autoadmit.com/thread.php?thread_id=3986533&forum_id=2#36127759) |
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Date: May 25th, 2018 4:33 PM Author: Cerise theater stage what's the diff between a 998 and a FRCP 68 offer of judgment? in biglaw lit, a rule 68 offer of judgment is just kinda lulzy (http://www.autoadmit.com/thread.php?thread_id=3986533&forum_id=2#36127769) |
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Date: May 25th, 2018 4:36 PM Author: vigorous wrinkle digit ratio plaintiff can use them as well. It's also just more of a "thing" in CA. For whatever reason most of the Rule 68 offers I've seen have been like insults. "Send him a Rule 68 for $5,000 to show him what we think of his case!" Yeah great litigation strategy there. (http://www.autoadmit.com/thread.php?thread_id=3986533&forum_id=2#36127792) |
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Date: May 25th, 2018 5:12 PM Author: offensive native Irl lol (http://www.autoadmit.com/thread.php?thread_id=3986533&forum_id=2#36127991) |
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Date: May 26th, 2018 5:57 PM Author: Lilac french locale place of business I make them in most of my cases. Arizona's Rule 68 allows for doubled taxable costs (the biggest usually being depositions) and recovery of expert witness fees, which typically aren't otherwise recoverable. (http://www.autoadmit.com/thread.php?thread_id=3986533&forum_id=2#36132942) |
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Date: May 26th, 2018 5:51 PM Author: Lilac french locale place of business Arizona's Rule 68 allows any party to send them. I wonder how many states are like that. (http://www.autoadmit.com/thread.php?thread_id=3986533&forum_id=2#36132915) |
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Date: May 25th, 2018 4:32 PM Author: frisky effete philosopher-king parlour Attorney just called me back. Case just settled for limits of 50K. (http://www.autoadmit.com/thread.php?thread_id=3986533&forum_id=2#36127765) |
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Date: May 25th, 2018 4:33 PM Author: Provocative Copper House Pervert just another $20k friday for CSLG (http://www.autoadmit.com/thread.php?thread_id=3986533&forum_id=2#36127772) |
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Date: May 26th, 2018 2:36 PM Author: floppy jet travel guidebook menage (http://www.autoadmit.com/thread.php?thread_id=3986533&forum_id=2#36132006) |
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Date: May 25th, 2018 4:33 PM Author: Racy ratface home 180 (http://www.autoadmit.com/thread.php?thread_id=3986533&forum_id=2#36127776) |
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Date: May 25th, 2018 4:34 PM Author: Cerise theater stage 180
what are the damages? does ur client have UIM? |
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Date: May 25th, 2018 4:35 PM Author: frisky effete philosopher-king parlour Unfortunately, no UIM. (http://www.autoadmit.com/thread.php?thread_id=3986533&forum_id=2#36127785) |
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Date: May 26th, 2018 6:03 PM Author: sable concupiscible useless brakes box office You got $20k for a case that’s been pending for nine months? That’s hard work bro (http://www.autoadmit.com/thread.php?thread_id=3986533&forum_id=2#36132950) |
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Date: May 25th, 2018 4:36 PM Author: wonderful church building bbw "It is our understanding from that your insured's policy limits are $50,000." (http://www.autoadmit.com/thread.php?thread_id=3986533&forum_id=2#36127790) |
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Date: May 25th, 2018 4:37 PM Author: Provocative Copper House Pervert and CSLG still had his full offer accepted from that letter. (http://www.autoadmit.com/thread.php?thread_id=3986533&forum_id=2#36127795) |
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Date: May 25th, 2018 4:39 PM Author: Cerise theater stage (http://www.autoadmit.com/thread.php?thread_id=3986533&forum_id=2#36127800) |
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Date: May 25th, 2018 4:48 PM Author: Wine multi-colored hospital old irish cottage But the prestige (http://www.autoadmit.com/thread.php?thread_id=3986533&forum_id=2#36127839) |
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Date: May 25th, 2018 4:38 PM Author: peach resort Isn't $50K settlement on $25k+ in specials kind of shitty. Thought the rule of thumb was 3x Specials (http://www.autoadmit.com/thread.php?thread_id=3986533&forum_id=2#36127799) |
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Date: May 25th, 2018 4:41 PM Author: frisky effete philosopher-king parlour That's not true at all in California. It hasn't been 3x medical specials in 20 years. (http://www.autoadmit.com/thread.php?thread_id=3986533&forum_id=2#36127812) |
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Date: May 25th, 2018 4:42 PM Author: vigorous wrinkle digit ratio $50K was policy limit. (http://www.autoadmit.com/thread.php?thread_id=3986533&forum_id=2#36127817) |
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Date: May 25th, 2018 4:50 PM Author: burgundy stage 3X actuals as a baseline is some old school shit. I almost regard it as a myth that never truly existed. (http://www.autoadmit.com/thread.php?thread_id=3986533&forum_id=2#36127847) |
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Date: May 25th, 2018 4:53 PM Author: Buff drunken station Not an expert but I feel like it is more like specials +30-40 percent to cover the contingency fees (http://www.autoadmit.com/thread.php?thread_id=3986533&forum_id=2#36127876) |
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Date: May 25th, 2018 5:10 PM Author: Wine multi-colored hospital old irish cottage $50k policy limit (http://www.autoadmit.com/thread.php?thread_id=3986533&forum_id=2#36127984) |
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Date: May 25th, 2018 4:41 PM Author: Rebellious incel round eye 180. Wish we had all these threads archived on a Solo Board so we can find them when we cut the wagecuck shackles (http://www.autoadmit.com/thread.php?thread_id=3986533&forum_id=2#36127811) |
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Date: May 25th, 2018 7:03 PM Author: Stimulating Tank (http://www.autoadmit.com/thread.php?thread_id=3986533&forum_id=2#36128668) |
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Date: May 25th, 2018 4:43 PM Author: frisky effete philosopher-king parlour On a side note. Funny e-mail exchange between me and Lenkov today: https://imgur.com/a/CbPDofN (http://www.autoadmit.com/thread.php?thread_id=3986533&forum_id=2#36127819) |
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Date: May 25th, 2018 4:44 PM Author: vigorous wrinkle digit ratio lol (http://www.autoadmit.com/thread.php?thread_id=3986533&forum_id=2#36127822) |
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Date: May 25th, 2018 4:44 PM Author: umber doctorate (http://www.autoadmit.com/thread.php?thread_id=3986533&forum_id=2#36127824) |
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Date: May 25th, 2018 4:44 PM Author: Cerise theater stage ljl.
is katherine hot, whoever she is? |
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Date: May 25th, 2018 4:51 PM Author: frisky effete philosopher-king parlour No clue. Never met her. (http://www.autoadmit.com/thread.php?thread_id=3986533&forum_id=2#36127854) |
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Date: May 25th, 2018 4:51 PM Author: 180 coral stage (http://www.autoadmit.com/thread.php?thread_id=3986533&forum_id=2#36127863) |
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Date: May 25th, 2018 5:04 PM Author: Racy ratface home chandler has had some good phone exchanges with adjusters lately. I don't know if he wants them shared though (http://www.autoadmit.com/thread.php?thread_id=3986533&forum_id=2#36127946) |
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Date: May 25th, 2018 5:09 PM Author: Wine multi-colored hospital old irish cottage Lmao. Who is he? ID? (http://www.autoadmit.com/thread.php?thread_id=3986533&forum_id=2#36127977) |
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Date: May 25th, 2018 5:11 PM Author: vigorous wrinkle digit ratio he is the Washington Generals to CSLG's Harlem Globetrotter schtick (http://www.autoadmit.com/thread.php?thread_id=3986533&forum_id=2#36127987) |
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Date: May 25th, 2018 5:39 PM Author: Cerise theater stage (http://www.autoadmit.com/thread.php?thread_id=3986533&forum_id=2#36128172) |
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Date: May 25th, 2018 5:44 PM Author: Confused jade school cafeteria coldplay fan (http://www.autoadmit.com/thread.php?thread_id=3986533&forum_id=2#36128214) |
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Date: May 25th, 2018 9:16 PM Author: Chartreuse national pisswyrm Pls update with anymore Lenkov correspondence. (http://www.autoadmit.com/thread.php?thread_id=3986533&forum_id=2#36129186) |
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Date: May 27th, 2018 12:13 AM Author: Cerise theater stage (http://www.autoadmit.com/thread.php?thread_id=3986533&forum_id=2#36134382) |
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Date: May 26th, 2018 6:00 PM Author: Lilac french locale place of business Why are you always dealing with that guy? (http://www.autoadmit.com/thread.php?thread_id=3986533&forum_id=2#36132947) |
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Date: May 27th, 2018 12:19 AM Author: aphrodisiac dog poop Jeffrey M. Lenkov is nationally recognized by many as the lawyer to hire when faced with high stakes litigation. (http://www.autoadmit.com/thread.php?thread_id=3986533&forum_id=2#36134402) |
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Date: May 27th, 2018 12:20 AM Author: Cerise theater stage (http://www.autoadmit.com/thread.php?thread_id=3986533&forum_id=2#36134412) |
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Date: May 27th, 2018 2:05 AM Author: Lilac french locale place of business *CSLG roaming around with his big bag of stakes* (http://www.autoadmit.com/thread.php?thread_id=3986533&forum_id=2#36134710) |
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Date: May 26th, 2018 6:05 PM Author: sable concupiscible useless brakes box office Lol 190 (http://www.autoadmit.com/thread.php?thread_id=3986533&forum_id=2#36132957) |
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Date: May 25th, 2018 7:05 PM Author: White alcoholic cruise ship jap 180 (http://www.autoadmit.com/thread.php?thread_id=3986533&forum_id=2#36128677) |
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Date: May 25th, 2018 7:10 PM Author: Zombie-like indian lodge Riddled with typos (http://www.autoadmit.com/thread.php?thread_id=3986533&forum_id=2#36128690) |
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Date: May 26th, 2018 6:23 PM Author: exciting center Damn u u are way better at this than me (http://www.autoadmit.com/thread.php?thread_id=3986533&forum_id=2#36132994) |