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Chandler -- tips ITT
| aphrodisiac persian bawdyhouse | 12/06/18 |
| Thriller bespoke piazza new version | 12/06/18 |
| aphrodisiac persian bawdyhouse | 12/06/18 |
| Thriller bespoke piazza new version | 12/06/18 |
| aphrodisiac persian bawdyhouse | 12/06/18 |
| Thriller bespoke piazza new version | 12/06/18 |
| aphrodisiac persian bawdyhouse | 12/06/18 |
| Thriller bespoke piazza new version | 12/06/18 |
| aphrodisiac persian bawdyhouse | 12/06/18 |
| Thriller bespoke piazza new version | 12/06/18 |
| aphrodisiac persian bawdyhouse | 12/06/18 |
| Thriller bespoke piazza new version | 12/06/18 |
| Thriller bespoke piazza new version | 12/06/18 |
| aphrodisiac persian bawdyhouse | 12/06/18 |
| Thriller bespoke piazza new version | 12/06/18 |
| aphrodisiac persian bawdyhouse | 12/06/18 |
| Thriller bespoke piazza new version | 12/06/18 |
| aphrodisiac persian bawdyhouse | 12/06/18 |
| Vermilion Address | 12/06/18 |
| aphrodisiac persian bawdyhouse | 12/12/18 |
| Thriller bespoke piazza new version | 12/12/18 |
| aphrodisiac persian bawdyhouse | 12/12/18 |
| Olive famous landscape painting | 12/12/18 |
| aphrodisiac persian bawdyhouse | 12/12/18 |
| Olive famous landscape painting | 12/12/18 |
| aphrodisiac persian bawdyhouse | 12/12/18 |
| Olive famous landscape painting | 12/12/18 |
| Thriller bespoke piazza new version | 12/12/18 |
| aphrodisiac persian bawdyhouse | 12/12/18 |
| Thriller bespoke piazza new version | 12/12/18 |
Poast new message in this thread
Date: December 6th, 2018 1:31 PM Author: aphrodisiac persian bawdyhouse (http://www.autoadmit.com/thread.php?thread_id=4150349&forum_id=2#37361033) |
Date: December 6th, 2018 1:39 PM Author: Thriller bespoke piazza new version Give them a declaration of no assets as descriptive as possible making your clients seem as poor as possible and indicating no excess insurance
Tell the defense your client is judgment proof, say the standard “blood out of a turnip line”
Tell them your client will just declare bankruptcy if a judgment is received against him personally over insurance limits. What are your limits? |
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Date: December 6th, 2018 1:41 PM Author: aphrodisiac persian bawdyhouse thank you for the advice.
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Date: December 6th, 2018 1:43 PM Author: Thriller bespoke piazza new version How are you defending the case then? (http://www.autoadmit.com/thread.php?thread_id=4150349&forum_id=2#37361119) |
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Date: December 6th, 2018 1:44 PM Author: aphrodisiac persian bawdyhouse (http://www.autoadmit.com/thread.php?thread_id=4150349&forum_id=2#37361125) |
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Date: December 6th, 2018 1:45 PM Author: Thriller bespoke piazza new version Tell defense you’re doing it pro bono then. If he’s rich enough to pay an attorney, they’d never drop it without payment (http://www.autoadmit.com/thread.php?thread_id=4150349&forum_id=2#37361138) |
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Date: December 6th, 2018 1:46 PM Author: aphrodisiac persian bawdyhouse (http://www.autoadmit.com/thread.php?thread_id=4150349&forum_id=2#37361145) |
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Date: December 6th, 2018 1:52 PM Author: Thriller bespoke piazza new version Lol at thinking a plaintiff’s subrogation firm would ever read an answer. That shit is volume. Each attorney has 300-500 cases.
Not sure about affirmative defenses but I’d just put the standard comparative fault defenses. Same ones from a PI suit. Maybe one extra one about how nationwide isn’t subrogated to the rights of the insured, also one about how nationwide didn’t make their insured “whole” which is a prerequisite of subrogation. |
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Date: December 6th, 2018 1:54 PM Author: aphrodisiac persian bawdyhouse (http://www.autoadmit.com/thread.php?thread_id=4150349&forum_id=2#37361207) |
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Date: December 6th, 2018 1:55 PM Author: Thriller bespoke piazza new version Declaration of no assets is by far the best thing to resolve these quickly and without payment.
Make sure to demand jury trial. Subrogation firms take the position you’re not entitled to one in a subrogation action which is incorrect. |
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Date: December 6th, 2018 1:56 PM Author: aphrodisiac persian bawdyhouse (http://www.autoadmit.com/thread.php?thread_id=4150349&forum_id=2#37361231) |
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Date: December 6th, 2018 2:01 PM Author: Thriller bespoke piazza new version Declaration of client name.
1. I, (client name) was involved in an automobile collision on (DATE) at approximately (3:00 pm). The other driver was named (other driver name)
2. I understand (other driver’s) insurance company Nationwide, is making a subrogation claim against me for damages.
3. I did not have any applicable insurance policy on the date of the accident.
4. I am currently unemployed, on welfare, on food stamps etc.
5. I only have 200 in bank account.
6. I own no property that could be used to satisfy a judgment.
7. Etc
I declare the following under penalty of perjury on (date) in (city state) |
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Date: December 6th, 2018 2:01 PM Author: Thriller bespoke piazza new version By the way, they can suspend your client’s license since he was uninsured via a DL-30 if there is an unpaid judgment against him for this accident. Do not let it get to that. (http://www.autoadmit.com/thread.php?thread_id=4150349&forum_id=2#37361271) |
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Date: December 6th, 2018 2:03 PM Author: aphrodisiac persian bawdyhouse (http://www.autoadmit.com/thread.php?thread_id=4150349&forum_id=2#37361276) |
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Date: December 6th, 2018 2:04 PM Author: Thriller bespoke piazza new version Take the position of not paying first. These firms cave most of the time. Offering money quickly gives the plaintiff confidence. (http://www.autoadmit.com/thread.php?thread_id=4150349&forum_id=2#37361284) |
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Date: December 6th, 2018 2:08 PM Author: aphrodisiac persian bawdyhouse (http://www.autoadmit.com/thread.php?thread_id=4150349&forum_id=2#37361312) |
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Date: December 6th, 2018 2:09 PM Author: Thriller bespoke piazza new version Never heard of him. (http://www.autoadmit.com/thread.php?thread_id=4150349&forum_id=2#37361322) |
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Date: December 6th, 2018 2:09 PM Author: aphrodisiac persian bawdyhouse cool. anyway, really appreciate your help. (http://www.autoadmit.com/thread.php?thread_id=4150349&forum_id=2#37361325) |
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Date: December 6th, 2018 1:46 PM Author: Vermilion Address cr (http://www.autoadmit.com/thread.php?thread_id=4150349&forum_id=2#37361146) |
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Date: December 12th, 2018 11:59 AM Author: aphrodisiac persian bawdyhouse chandler, you around? (http://www.autoadmit.com/thread.php?thread_id=4150349&forum_id=2#37395344) |
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Date: December 12th, 2018 12:02 PM Author: Thriller bespoke piazza new version yeah man in the office, trial is done. (http://www.autoadmit.com/thread.php?thread_id=4150349&forum_id=2#37395366) |
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Date: December 12th, 2018 12:06 PM Author: aphrodisiac persian bawdyhouse damn, what happ to taking time off?
how useful would it be for me to challenge liability in this subro claim? i'm trying to disincentivize the ins company from pursuing this and instead accepting a nominal settlement.
client fucked up here (was under influence and left the scene of accident) but there is an argument that the other driver actually hit him. |
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Date: December 12th, 2018 12:10 PM Author: Olive famous landscape painting isn't that more of a strict liability/negligence per se thing? (http://www.autoadmit.com/thread.php?thread_id=4150349&forum_id=2#37395416) |
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Date: December 12th, 2018 12:12 PM Author: aphrodisiac persian bawdyhouse is it? if im under the influence and driving and someone else hits me, then i need to pay up in a subro claim? (http://www.autoadmit.com/thread.php?thread_id=4150349&forum_id=2#37395435) |
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Date: December 12th, 2018 12:13 PM Author: Olive famous landscape painting oh I thought you meant he was charged & convicted (http://www.autoadmit.com/thread.php?thread_id=4150349&forum_id=2#37395452) |
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Date: December 12th, 2018 12:16 PM Author: aphrodisiac persian bawdyhouse yea he was charged with driving under the influence. but thats different from actually causing the motor vehicle accident that gave rise to the subro claim. (http://www.autoadmit.com/thread.php?thread_id=4150349&forum_id=2#37395470) |
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Date: December 12th, 2018 12:18 PM Author: Olive famous landscape painting and that's the whole point of comparative negligence, right? there's absolutely no chance in hell that a jury buys that the defendant caused the accident when the plaintiff was snockered to the gills (http://www.autoadmit.com/thread.php?thread_id=4150349&forum_id=2#37395493) |
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Date: December 12th, 2018 12:15 PM Author: Thriller bespoke piazza new version i have like 50 missed calls man. i can't take time off. clients bitching at me. (http://www.autoadmit.com/thread.php?thread_id=4150349&forum_id=2#37395466) |
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Date: December 12th, 2018 12:13 PM Author: aphrodisiac persian bawdyhouse how do i phrase that if they dont agree to settle then my client will be forced to file bankruptcy if there is an adverse award against her? (http://www.autoadmit.com/thread.php?thread_id=4150349&forum_id=2#37395448) |
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Date: December 12th, 2018 12:16 PM Author: Thriller bespoke piazza new version "If a large judgment is entered against my client, she will declare bankruptcy as she has an inability to pay and no significant assets for which to pay off a debt." (http://www.autoadmit.com/thread.php?thread_id=4150349&forum_id=2#37395474) |