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Poast new message in this thread
Date: May 25th, 2018 4:24 PM Author: Pink provocative bbw nursing home 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: Pink provocative bbw nursing home 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: Submissive prole (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: Big windowlicker macaca 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: Pink provocative bbw nursing home 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: Big windowlicker macaca 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: Pink provocative bbw nursing home 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: Shivering Heaven 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: Pink provocative bbw nursing home 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: Hideous Chartreuse Multi-billionaire Stag Film 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: Shivering Heaven 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: French Supple Principal's Office 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: Bateful stage 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: Amethyst brunch 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: Pink provocative bbw nursing home This is shitlaw, not biglaw.
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Date: May 25th, 2018 4:30 PM Author: laughsome sadistic haunted graveyard pozpig 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: marvelous rose mood double fault 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: mint floppy indian lodge hissy fit (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: laughsome sadistic haunted graveyard pozpig 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: Khaki ladyboy 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: Pink provocative bbw nursing home 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: Shivering Heaven 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: laughsome sadistic haunted graveyard pozpig 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 4:41 PM Author: Khaki ladyboy 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: Poppy vibrant goyim 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: Splenetic national (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: Big windowlicker macaca 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: Shivering Heaven 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: Splenetic national (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: at-the-ready elite site 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: Pink provocative bbw nursing home 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: French Supple Principal's Office (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: Poppy vibrant goyim (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: Cream stimulating rehab 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: Comical wrinkle 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: Pink provocative bbw nursing home 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: out-of-control internet-worthy corner 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: Big windowlicker macaca 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: Talking Azn 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: honey-headed travel guidebook market 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: Shivering Heaven 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: honey-headed travel guidebook market 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: obsidian histrionic feces 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: Hideous Chartreuse Multi-billionaire Stag Film 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: Hideous Chartreuse Multi-billionaire Stag Film 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: Pink provocative bbw nursing home 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: Talking Azn 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: Bateful stage (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: Big windowlicker macaca 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: Shivering Heaven 180
what are the damages? does ur client have UIM? |
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Date: May 25th, 2018 4:35 PM Author: Pink provocative bbw nursing home 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: mint floppy indian lodge hissy fit 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: pearl passionate locus "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: Talking Azn 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: Shivering Heaven (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: Comical wrinkle 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: razzmatazz unhinged den 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: Pink provocative bbw nursing home 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: honey-headed travel guidebook market $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: Maize curious puppy 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: white electric useless brakes 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: Comical wrinkle $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: godawful beady-eyed tattoo depressive 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: Carnelian Bespoke Selfie (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: Pink provocative bbw nursing home 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: honey-headed travel guidebook market 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: laughsome sadistic haunted graveyard pozpig (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: Shivering Heaven ljl.
is katherine hot, whoever she is? |
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Date: May 25th, 2018 4:51 PM Author: Pink provocative bbw nursing home 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: Submissive prole (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: Big windowlicker macaca 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: Comical wrinkle 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: honey-headed travel guidebook market 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: Shivering Heaven (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: Splenetic national (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: violent gaping lay 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: Shivering Heaven (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: Hideous Chartreuse Multi-billionaire Stag Film 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: violet hyperventilating 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: Shivering Heaven (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: Hideous Chartreuse Multi-billionaire Stag Film *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: mint floppy indian lodge hissy fit 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: mauve base mediation 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: drab hall clown Riddled with typos (http://www.autoadmit.com/thread.php?thread_id=3986533&forum_id=2#36128690) |
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