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Poast new message in this thread
Date: May 25th, 2018 4:24 PM Author: Pea-brained stirring candlestick maker 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: Pea-brained stirring candlestick maker 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: Vigorous Stage Kitty Cat (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: Milky prole gaping 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: Pea-brained stirring candlestick maker 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: Milky prole gaping 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: Pea-brained stirring candlestick maker 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: At-the-ready puce pervert electric furnace 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: Pea-brained stirring candlestick maker 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: Obsidian Magical Filthpig 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: At-the-ready puce pervert electric furnace 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: Wonderful Sapphire Church Building Tattoo 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: rebellious elastic band orchestra pit 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: Trip alcoholic station yarmulke 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: Pea-brained stirring candlestick maker This is shitlaw, not biglaw.
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Date: May 25th, 2018 4:30 PM Author: pearl forum 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: Lilac multi-colored locale gaming laptop 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: tripping free-loading school (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: pearl forum 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: Pearly gay wizard 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: Pea-brained stirring candlestick maker 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: At-the-ready puce pervert electric furnace 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: pearl forum 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: Narrow-minded Nursing Home (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: Exhilarant Mauve Antidepressant Drug State (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: Pearly gay wizard 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: bespoke house regret 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: dull geriatric deer antler (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: Milky prole gaping 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: At-the-ready puce pervert electric furnace 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: dull geriatric deer antler (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: Mildly Autistic Rehab 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: Pea-brained stirring candlestick maker 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: Wonderful Sapphire Church Building Tattoo (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: bespoke house regret (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: fragrant bright space roommate 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: Domesticated half-breed 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: Pea-brained stirring candlestick maker 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: passionate azure theater stage 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: Milky prole gaping 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: razzle-dazzle vermilion lettuce 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: twinkling floppy incel 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: At-the-ready puce pervert electric furnace 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: twinkling floppy incel 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: Soul-stirring Mood Bawdyhouse 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: Obsidian Magical Filthpig 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: Obsidian Magical Filthpig 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: Pea-brained stirring candlestick maker 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: razzle-dazzle vermilion lettuce 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: rebellious elastic band orchestra pit (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: Milky prole gaping 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: At-the-ready puce pervert electric furnace 180
what are the damages? does ur client have UIM? |
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Date: May 25th, 2018 4:35 PM Author: Pea-brained stirring candlestick maker 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: tripping free-loading school 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: Slate Out-of-control Jew Son Of Senegal "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: razzle-dazzle vermilion lettuce 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: At-the-ready puce pervert electric furnace (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: Domesticated half-breed 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: Abusive philosopher-king boiling water 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: Pea-brained stirring candlestick maker 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: twinkling floppy incel $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: Razzmatazz Becky Temple 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: Sticky Hominid Puppy 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: Domesticated half-breed $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: Primrose newt 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: ocher kitchen (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: Pea-brained stirring candlestick maker 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: twinkling floppy incel 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: pearl forum (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: At-the-ready puce pervert electric furnace ljl.
is katherine hot, whoever she is? |
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Date: May 25th, 2018 4:51 PM Author: Pea-brained stirring candlestick maker 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: Vigorous Stage Kitty Cat (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: Milky prole gaping 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: Domesticated half-breed 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: twinkling floppy incel 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: At-the-ready puce pervert electric furnace (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: dull geriatric deer antler (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: supple queen of the night 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: At-the-ready puce pervert electric furnace (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: Obsidian Magical Filthpig 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: Coiffed vengeful locus organic girlfriend 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: At-the-ready puce pervert electric furnace (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: Obsidian Magical Filthpig *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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