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| Cerebral Maniacal University Preventive Strike | 05/25/18 |
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| Cerebral Maniacal University Preventive Strike | 05/25/18 |
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| Cerebral Maniacal University Preventive Strike | 05/25/18 |
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| Provocative shimmering wrinkle hell | 05/26/18 |
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| Cerebral Maniacal University Preventive Strike | 05/25/18 |
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| Lime multi-billionaire | 05/26/18 |
| wonderful bisexual dilemma water buffalo | 05/25/18 |
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| Cerebral Maniacal University Preventive Strike | 05/25/18 |
| Fragrant new version rigor | 05/25/18 |
| flirting library | 05/25/18 |
| Cobalt Center | 05/25/18 |
| Cerebral Maniacal University Preventive Strike | 05/25/18 |
| razzle juggernaut | 05/25/18 |
| wonderful bisexual dilemma water buffalo | 05/25/18 |
| House-broken adventurous legal warrant parlour | 05/25/18 |
| Fragrant new version rigor | 05/25/18 |
| Cobalt Center | 05/25/18 |
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| Cobalt Center | 05/27/18 |
| Provocative shimmering wrinkle hell | 05/26/18 |
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| apoplectic excitant ratface bawdyhouse | 05/26/18 |
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| Cerebral Maniacal University Preventive Strike | 05/25/18 |
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Poast new message in this thread
Date: May 25th, 2018 4:24 PM Author: Cerebral Maniacal University Preventive Strike 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: Cerebral Maniacal University Preventive Strike 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: razzle juggernaut (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: wonderful bisexual dilemma water buffalo 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: Cerebral Maniacal University Preventive Strike 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: wonderful bisexual dilemma water buffalo 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: Cerebral Maniacal University Preventive Strike 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: Cobalt Center 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: Cerebral Maniacal University Preventive Strike 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: Provocative shimmering wrinkle hell 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: Cobalt Center 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: henna fat ankles 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: Lime multi-billionaire 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: big church 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: Cerebral Maniacal University Preventive Strike This is shitlaw, not biglaw.
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Date: May 25th, 2018 4:30 PM Author: flirting library 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: pearly deranged cruise ship 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: apoplectic excitant ratface bawdyhouse (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: flirting library 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: Floppy selfie stage 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: Cerebral Maniacal University Preventive Strike 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: Cobalt Center 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: flirting library 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: concupiscible plum stage (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: stimulating station (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: Floppy selfie stage 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: Bipolar sneaky criminal 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: diverse pit clown (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: wonderful bisexual dilemma water buffalo 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: Cobalt Center 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: diverse pit clown (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: heady dull piazza international law enforcement agency 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: Cerebral Maniacal University Preventive Strike 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: henna fat ankles (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: Bipolar sneaky criminal (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: Soggy wagecucks business firm 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: House-broken adventurous legal warrant parlour 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: Cerebral Maniacal University Preventive Strike 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: mildly autistic church building dopamine 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: wonderful bisexual dilemma water buffalo 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: electric step-uncle's house 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: Fragrant new version rigor 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: Cobalt Center 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: Fragrant new version rigor 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: grizzly tantric whorehouse 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: Provocative shimmering wrinkle hell 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: Provocative shimmering wrinkle hell 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: Cerebral Maniacal University Preventive Strike 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: electric step-uncle's house 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: Lime multi-billionaire (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: wonderful bisexual dilemma water buffalo 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: Cobalt Center 180
what are the damages? does ur client have UIM? |
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Date: May 25th, 2018 4:35 PM Author: Cerebral Maniacal University Preventive Strike 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: apoplectic excitant ratface bawdyhouse 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: odious sienna personal credit line theater stage "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: electric step-uncle's house 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: Cobalt Center (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: House-broken adventurous legal warrant parlour 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: unholy aphrodisiac dog poop 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: Cerebral Maniacal University Preventive Strike 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: Fragrant new version rigor $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: Federal Space Gay Wizard 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: Cowardly Harsh Corn Cake 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: House-broken adventurous legal warrant parlour $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: stirring slimy indian lodge 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: embarrassed to the bone racy menage old irish cottage (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: Cerebral Maniacal University Preventive Strike 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: Fragrant new version rigor 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: flirting library (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: Cobalt Center ljl.
is katherine hot, whoever she is? |
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Date: May 25th, 2018 4:51 PM Author: Cerebral Maniacal University Preventive Strike 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: razzle juggernaut (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: wonderful bisexual dilemma water buffalo 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: House-broken adventurous legal warrant parlour 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: Fragrant new version rigor 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: Cobalt Center (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: diverse pit clown (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: azure misunderstood crackhouse 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: Cobalt Center (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: Provocative shimmering wrinkle hell 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: sepia pontificating digit ratio orchestra pit 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: Cobalt Center (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: Provocative shimmering wrinkle hell *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: apoplectic excitant ratface bawdyhouse 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: Orchid Appetizing Nursing Home Goal In Life 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: yellow den scourge upon the earth Riddled with typos (http://www.autoadmit.com/thread.php?thread_id=3986533&forum_id=2#36128690) |
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Date: May 25th, 2018 7:19 PM Author: Cerebral Maniacal University Preventive Strike Yup. I make lots of typos... I'm an ambulance chaser and I rarely have time to proof read. Doesn't change the fact I settle for limits all day long. (http://www.autoadmit.com/thread.php?thread_id=3986533&forum_id=2#36128720) |
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Date: May 26th, 2018 2:26 PM Author: 180 ruby state stain 180 (http://www.autoadmit.com/thread.php?thread_id=3986533&forum_id=2#36131957) |
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Date: May 27th, 2018 12:16 AM Author: sepia pontificating digit ratio orchestra pit 180 (http://www.autoadmit.com/thread.php?thread_id=3986533&forum_id=2#36134391) |
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Date: May 27th, 2018 12:19 AM Author: flirting library (http://www.autoadmit.com/thread.php?thread_id=3986533&forum_id=2#36134405) |
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Date: May 27th, 2018 12:20 AM Author: Lime multi-billionaire JFC rock hard (http://www.autoadmit.com/thread.php?thread_id=3986533&forum_id=2#36134408) |
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Date: May 27th, 2018 12:21 AM Author: Cobalt Center (http://www.autoadmit.com/thread.php?thread_id=3986533&forum_id=2#36134415) |
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Date: May 26th, 2018 6:23 PM Author: Smoky Fighting Tanning Salon Damn u u are way better at this than me (http://www.autoadmit.com/thread.php?thread_id=3986533&forum_id=2#36132994) |