monthly inspiration january 2015li companies have been retained by the state of california to assist...

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My family and I traveled to Israel with our syna- gogue over the holiday and while I was gone, we had the best month in file assignments in the history of the firm. I guess that I should go away more oſten! In December, we opened 203 new cases. Our average for the prior 11 months had been 137.5. About 30 of the files came from one client who decided to close its staff counsel office, but even account- ing for that single mass assignment, it appears that our business development efforts are paying off. e assignments in December came from 72 different cli- ents. ese include the largest insurance companies such as AIG and State Farm, and medium and small insurers such as Sentry and National Indemnity. ese also include direct assignments from some of the nation’s largest corporations such as McDonald’s and General Motors, as well as medium and small companies such as Old Dominion Freight Line and Austgen Properties. Forty-three of these new assignments were worker’s compen- sation assignments; while the average for the prior 11 months had been 30.5. Our worker’s compensation practice is vibrant and growing, with a diversified client base evidenced by 20 clients send- ing worker’s compensation assignments in December alone. I am very proud of our diversity of clien- tele and of our success in marketing our services. Almost every one of these 203 assignments came from clients who are already clients of the firm. at means that we are doing a good job on existing files and, more importantly, on existing relationships, so that the claim profes- sionals who make the assignments are January 2015 “If you can’t fly then run, if you can’t run then walk, if you can’t walk then crawl, but whatever you do, you have to keep moving forward.” - Dr. Marn Luther King, Jr. Monthly Inspiration I Should Go Away More Often BY: BOB KOPKA N e W C l i E t s N pleased to continue to seek our services. is speaks well of each and every one of us. e credit goes to every partner that reaches out to clients oſten, to every at- torney that thinks creatively and moves the case to an early favorable resolution, to every paralegal that interviews the insureds and scans the documents to develop the defenses and marshal the evidence, to every secretary that em- ploys his or her skill to make sure that our pleadings look professional and are properly formatted and filed, to every clerk and receptionist, to every manager and to our billing and IT department. It is the sum of all of our parts that makes us great and successful. When an organization like ours works together, we excel. While in Israel, I saw that kind of spirit everywhere I went. Israelis understand how to defeat ter- ror with spirit. ere were many terror attacks while I was in Israel and people are certainly frightened; but they don’t let their fear defeat them or even disturb their work or their lives. People are out in cafes and bars, jogging and biking amidst increased police presence and a general alertness; but people are out. And they are doing amazing things. For the past 65 years, Israel has suffered a water shortage. Yet, today, Israel has an abundance of water. Israel is now the world’s leader in water conservation and waste recycling. Israel recycles and reuses 89% of its water. e next best country for water reuse is Spain at 24%. America is at 12%. How did they do it? Article continued on page 2

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  • My family and I traveled to Israel with our syna-gogue over the holiday and while I was gone, we had the best month in file assignments in the history of the firm. I

    guess that I should go away more often!

    In December, we opened 203 new cases. Our average for the prior 11 months had been 137.5. About 30 of the files came from one client who decided to close its staff counsel office, but even account-ing for that single mass assignment, it appears that our business development efforts are paying off. The assignments in December came from 72 different cli-ents. These include the largest insurance companies such as AIG and State Farm, and medium and small insurers such as Sentry and National Indemnity. These also include direct assignments from some of the nation’s largest corporations such as McDonald’s and General Motors, as well as medium and small companies such as Old Dominion Freight Line and Austgen Properties. Forty-three of these new assignments were worker’s compen-sation assignments; while the average for the prior 11 months had been 30.5. Our worker’s compensation practice is vibrant and growing, with a diversified client base evidenced by 20 clients send-ing worker’s compensation assignments in December alone.

    I am very proud of our diversity of clien-tele and of our success in marketing our services. Almost every one of these 203 assignments came from clients who are already clients of the firm. That means that we are doing a good job on existing files and, more importantly, on existing relationships, so that the claim profes-sionals who make the assignments are

    KPD CONNECTJanuary 2015

    “If you can’t fly then run, if you can’t

    run then walk, if you can’t walk then

    crawl, but whatever you do, you

    have to keep moving forward.”

    - Dr. Martin Luther King, Jr.

    Monthly Inspiration

    I Should Go Away More OftenBY: BOB KOPKA

    N e W

    C l i E t sN

    pleased to continue to seek our services.

    This speaks well of each and every one of us. The credit goes to every partner that reaches out to clients often, to every at-torney that thinks creatively and moves the case to an early favorable resolution, to every paralegal that interviews the insureds and scans the documents to develop the defenses and marshal the evidence, to every secretary that em-ploys his or her skill to make sure that our pleadings look professional and are properly formatted and filed, to every clerk and receptionist, to every manager and to our billing and IT department. It is the sum of all of our parts that makes us great and successful.

    When an organization like ours works together, we excel. While in Israel, I saw that kind of spirit everywhere I went. Israelis understand how to defeat ter-ror with spirit. There were many terror attacks while I was in Israel and people are certainly frightened; but they don’t let their fear defeat them or even disturb their work or their lives. People are out in cafes and bars, jogging and biking amidst increased police presence and a general alertness; but people are out. And they are doing amazing things.

    For the past 65 years, Israel has suffered a water shortage. Yet, today, Israel has an abundance of water. Israel is now the world’s leader in water conservation and waste recycling. Israel recycles and reuses 89% of its water. The next best country for water reuse is Spain at 24%. America is at 12%. How did they do it?

    AMERICAN SALE CORP.

    Article continued on page 2

  • 2

    Gene Pinkus and Bob Abramson

    January 21, 2016

    Anti-Fraud Training SeminarFrankenmuth Insurance

    Upcoming

    Speaking Engagements They work creatively as a team, just like us. They use technology developed for military or other uses and apply them to civilian problems. We visited a water filtration plant that cleans and recycles 100% of the human waste produced by the 2.5 million people living in and around Tel Aviv for agricultural use. The waste water is recycled and purified to the point where it is safe and useful for Israel’s agricultural purposes. Israe-li companies have been retained by the State of California to assist the Golden State in coping with their persistent wa-ter shortage. Israel has the world’s big-gest and most efficient sea water desali-nation plant, and Israel gets more than 30% of its potable water from sea water desalination.

    Article continued from page 1

    We also visited the new Ariel Sharon Park, named for Israel’s former Prime Minister and war hero. When complet-ed, it will be larger than New York’s Cen-tral Park. Filled with trees and fountains, it will become the jewel of Tel Aviv. The entire park was built using all recycled material, on top of what used to be the garbage dump of Tel Aviv. Unfortunate-ly for the former Prime Minister, most people still call it by its former name: “Charia” which means “Shitsville.”

    Well, as you can see, I had a great trip and we had a great month. Here’s an idea: let’s keep up the success, even with me in the country!

    All My Best,

    Bob

    Bob and Wendy with Jerusalem on the horizon.

    Bob and Jack on the army base.

    Bob, Wendy, and Seth in the desert.

    Group photo on the beach in Tel Aviv.

    Kevin Plagens

    January 12, 2016

    Great Lakes Chapter of ASHI®, SE Michigan Group Guest Speaker

    Livonia, MIHome Inspection “Legal Contracts”

    Bob Kopka

    January 20, 2016

    RIMS Chicago Chapter January Holiday Party

    Chicago, ILCyber Security Crisis Panel

    SIU Investigations - The Real Cost, Initial Investigation, Indicators, EUO, Material Misrepresentation, Non-Cooperation Frankenmuth, MI

  • 3

    Congratulations

    As we start a new year, I wanted to again share our core values:

    • Treat all individuals with respect.• Aim to exceed expectations.• Seek to understand; recognize and learn what you do not know.• Concierge service on behalf of our clients will reap unlimited reward.

    I was thinking about the firm’s past, present, and future and found this quote which I believe emphasizes who KPD is, including all of us who work together, whatever the job.

    2016 - KPD: A Firm of LeadersBY: GENE PINKUS

    Mr. de Pree was a business innovator who fostered the idea of a corporation where “all voices are heard.” We strive for that goal today. Let’s be honest, we are brought together by work and we must always strive to work harder and smarter within the confines of our core values. Let’s continue with our outstanding efforts and we will continue to see the excellent results.

    To me, this quote recognizes that we are all leaders, as to move forward we must be focused together in furtherance of our core values. Clerks lead with friendliness, efficiency and performing day-to-day tasks, without which the firm would come to a standstill. Administrative assistants are in the office producing top quality work product and keeping attorneys and paralegals organized and focused to respond to the needs of the clients we proudly serve. At KPD everyone has interactions with our clients and we handle these relationships in a positive manner. Attorneys and paralegals produce the best legal work around and continue to enhance the reputation of KPD throughout the industry and the country. Our Shareholders are not only amazing attorneys, but they also continue to give back to the firm by being kind and generous to those who work with us, mentor attorneys on the rise, and help us to continue our growth. Our back office administrators, computer, and billing specialists, as well as our office managers keep us on the cutting edge of being able to outperform the competition in tough markets and are always looking at ways to improve the firm.

    Truth be told, everyone who works together at KPD demonstrates leadership qual-ities. We could not grow or continue to focus on our core values without everyone working together. If we all LEAD together, the firm’s future is secure!

    “THE FIRST RESPONSIBILITY OF A LEADER IS TO DEFINE REALITY. THE LAST IS TO SAY THANK YOU. IN BETWEEN, THE LEADER IS A SERVANT.”

    ----Max de Pree Eric Kairis of our Farming-ton Hills office has success-fully completed his studies at O.C.C. and is a Paralegal graduate.

    Racquel Rutledge of our Indianapolis office recent-ly graduated from Univer-sity of Indianapolis. She earned her Bachelor’s De-gree in Liberal Studies, ma-

    joring in organizational leadership and management.

  • 4

    All Fun and Games at the KPD Holiday Parties

  • All Fun and Games at the KPD Holiday Parties

    5

  • pointed out the graffiti laced door of the hippest night club in Tel Aviv, which, in an unspoken convention, only hosts gay Arabs on the third Tuesday of ev-ery month. Seems odd, right? She ex-plained that in Arab society, homosex-uality is shunned and not accepted. The gay men and women in these villages have nowhere to go except for this one venue, on the “down low.” While this all seems so odd, it is done as a form of fellowship and hope. Tel Aviv is mostly Jewish and yet, the club, which is not a gay club, but a popular egalitarian night club, hosts fellow citizens, who are very different and who do not usually inter-act in a positive way.

    I think Dr. King would have been proud of that gesture. In regard to the conflict with the Palestinians, Israel is not as tol-erant. Years of conflict have made Israe-lis wary of the intentions of their neigh-bors. America may have been heading down that path, a path of conflict and hatred, when Dr. King arose, and taught us the power of non-violence. I wish Israel and the Palestinians would have their own Dr. King; but alas, a man such as Martin Luther King, Jr. comes but once in a millennium.

    We are blessed to live in this nation and we aspire to be a shining beacon of hope for the rest of the world. I wish each of you a blessed Martin Luther King, Jr. Day.

    6

    Janet Markfull is Stepping

    Up for Kids

    Janet Markfull, of our Crown Point office, will be participating in the “Aon Step Up for Kids” event at the Aon Center in Chicago on January 31, 2016.

    Janet will be climbing 1623 steps to the top of the Aon Center to help raise money for Ann & Robert Lurie Chil-dren’s Hospital of Chicago. Please take a moment to visit her team page (mark-full-kordas) and make a donation to support a wonderful cause. Good luck, Janet!

    Dr. Martin Luther King, Jr. and IsraelBY: BOB KOPKA

    The graffiti-laced entrance to the night club in Tel Aviv.

    I want to wish everyone a wonderful Martin Lu-ther King, Jr. Day, a day of service and a day to reflect on the impact Dr. King had on our nation and on our world. We

    are privileged to live in a country that has been so influenced by his wisdom. Dr. King reminded us that we live by a creed, that all men are created equal, with equal rights and that, as Americans, we have mutual obligations to each other. Having just returned from my 13th trip to Israel, I have observed the contrasts between our nation’s understanding of equal rights and that of other nations. Dr. King supported the Jewish state and the Zionist aspiration to have a Jewish state. He acknowledged Israel’s right to defend itself against aggression. Speak-ing at the annual convention of the Rab-binical Assembly in 1968, Dr. King said:

    “Peace for Israel means security, and we must stand with all our might to protect her right to exist... Israel is one of the great outposts of democracy in the world, and a marvelous example of what can be done, how desert land can be transformed into an oasis of broth-erhood and democracy. Peace for Israel means security, and that security must be a reality.”

    In response to a student who had at-tacked Zionism during a dinner event with Dr. King in 1968, he said, “When people criticize Zionists, they mean Jews. You’re talking anti-Semitism.”

    Israel is indeed an outpost of democra-cy and tolerance. One of the most inter-esting afternoons of my recent trip was a “graffiti” tour of Tel Aviv. A group of us walked through a hip, older section of Tel Aviv with a PhD. Tour guide, who helped interpret the art, symbolism and great puns and plays on words in the graffiti. Many of the comments were calls for equality and hope. Our guide

    http://foundation.luriechildrens.org/site/TR/Events/StepUpforKids?team_id=33533&pg=team&fr_id=1590

  • 7

    Justin KiernickiJanet MarkfullJerry NewmanApril JaySam MilstoneLaura HagenowAngelo TestaTracey WetzsteinDawn BonneauKatie PorterKim RamsaySteve CouchAnnie LachowiczBob KopkaFred MuellerChristina EssexToni Angelucci

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    JAN

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    Randy GraffLaTonya RobinsonLiz HopkinsJim O’GallagherMichelle SarkoziSheila OseiDebra Lange

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    10

    JAN YEARS

    Happy

    Anniversary!KPD

    The Value of the Client ExperienceBY: DONNA MARKUS

    I recently had to call a credit card company, and was immediately received by an automated voice thanking me for my call, yet di-recting me to punch in a selection in order to route my call else-where. After following the instructions, I am finally routed to the correct department, but put on hold to wait—an estimated time of 14 minutes—for the next available representative. When the rep-resentative finally answers, not only was it difficult to understand

    them, but I was put on hold again so the representative could find a solution. I know that this is something that we have all experienced, but it got me thinking about the intro of “thank you for your call.” When you thank someone it is to show appreciation for something done. However, the frustrating rigmarole that I had experienced didn’t convey appreciation. My experience was negative, and made me feel that my time was wasted. I then thought: what does great service, or concierge service, look and feel like? Of course there are times that you don’t have the answer or an immediate solution and other times you may have to deliver bad news; but how do you still make it a positive experience that conveys appreciation?

    Looking back at experiences I have had and the details that made them great, I outlined a few things that stood out to me:

    1. Availability. Are you available when you are needed? Do you respond in a timely manner whether it is a telephone call or email? Does the service you provide make the client feel that you are there for them?

    2. Efficiency. Do you solve problems or answer questions the first time? Or does your client have to remind you or call again for the answer?

    3. Honesty. Our clients need to be able to trust you and our business practices in order to be comfortable with you.

    4. Personality. You can do all the right things, but it is important to make it an experience that they will remember.

    In the spirit of Dr. Martin Luther King, Jr., we will be volunteering our service to others. The same principles apply. When we volunteer we are making ourselves available and giving our time and attention to different organizations.

    We give time to a project whether it is for stocking a food shelf or cleaning bath-rooms. We work together to efficiently complete the project, which fosters com-radery as the collaboration of our different personalities make the experience worthwhile. Whether you are providing concierge service to our client or volun-teering your time and effort to an organization, you feel a sense of accomplishment that you provided great service.

    Please note that VPS banks will reset with the correct hours after the check on January 15, 2016. If you are planning on taking off before the banks are re-set, just let John or Monica know and we will make sure that this is reflected and approved.

    A Note About VPS Banks

  • In 1983, Jan Clark be-gan working as a legal secretary. Soon after she went back to school for her associ-ate degree

    and paralegal certificate. In 1997, Jan graduated from Indiana University of South Bend, and became a member of the St. Joseph County Para-legal Association, where she served as Secretary for 5 years.

    Jan joined the KPD family thirteen years ago as a paralegal for Jim Milstone in the South Bend office. When the office closed 3 years ago, she relocated to the Indianapolis office. Coming from the small town of Elkhart, moving to In-

    dianapolis was a big adjustment for Jan, but eventually she adapted to her new surroundings and loves it. She is ex-

    tremely glad that she was given the opportunity to move with KPD, because she loves her job and feels it is an honor to work for Jim Milstone and the firm.

    Jan and her high school sweetheart, Mitch, re-cently celebrated their 32nd wedding anniversa-ry. They have two grown children, Kelsi and Kyle,

    who also reside in Indianapolis. Jan and Mitch love riding their bicycles, and spend most of their summers boating on Geist Reservoir in the northeastern part of Indianapolis.

    Step into the Spotlight: Jan Clark

    8

    Celebrating the Holidays

    with Family

    Omar Castro, of the Buffalo Grove IT team, celebrated with his two children, Gabriel and Jocelyn.

    Jan Clark, a paralegal in our Indianapolis office, enjoyed the company of her two children: Kelsi and Kyle, daughter-in-law: Megan, and grand fur babies.

    Aimee Schatz, a partner in our Crown Point office celebrated the magic of the holidays with her husband and three boys aboard a Disney® Cruise.

    Community Service in Remembrance of Dr. King

    Office Volunteer LocationBuffalo Grove Recreation Center of Highland Park

    1207 Park Ave.Highland Park, IL 60035

    Chicago Ronald McDonald House 5444 South Drexel Chicago, IL

    Crown Point Food Bank of NWI2248 W. 35th AvenueGary, IN

    Farmington Hills Boys and Girls Clubs of SE Michigan 2677 Halsted Road, Suite 100 Farmington Hill, MI

    Indianapolis Gift of Water1025 Pine Hill WayCarmel, IN

    Once again, the firm intends to honor our nation and the extraordinary legacy of Dr. Martin Luther King, Jr. by offering our employees an opportunity to serve our communities in honor of Martin Luther King, Jr. Day. We have identified commu-nity service opportunities in the vicinities of each of our offices and we invite all of our employees to sign up for one of our service options for the day. We encourage everyone to participate in this opportunity to serve our communities and honor our country. The chart below lists the community service opportunities in which we will participate as a firm. A sign-up sheet with times and details will be sent out in an e-mail soon.

  • Holiday Spirit at KPD: Oh What Fun!

    The KPD offices spread some cheer this year with a festive event in their offices. Buffalo Grove enjoyed a Secret Santa gift exchange, Chicago wore their best Ugly Holiday Sweaters and had a delicious cookie exchange, Farmington Hills donned their favorite Ugly Holiday Sweaters, and Indianapolis had a blast with a White El-ephant gift exchange.

    Buffalo Grove Chicago

    IndianapolisFarmington Hills

    9

    Brian D. King

    Farmington Hills OfficeAttorney

    Carolyn Duff

    Farmington Hills OfficeLegal Assistant

    Kevin Peurasaari

    Farmington Hills OfficeParalegal

    PICTURE OF THE MONTHB Y: DAV I D KOPKA

    This picture was featured on the WGN 5 pm News broadcast on December 9, 2015.

    Well done, David!

    Welcome to the Team

  • 10

    Upcoming Trials

    Congratulations to KPD on a success-ful charity drive for Covenant House Michigan and St. Jude House. The Farmington Hills office donated $600 to Covenant House Michigan, while the Illinois and Indiana offices collected $1600 in order to provide the wish list items and gift cards (pictured below) to

    2015 December Charity Drive

    There's Something About Leslie

    Leslie Pollie, a partner in our Indianapolis office, shares ten facts about herself that we may not have known.

    1. I started riding horses when I was four.

    2. I went to college to become a large animal vet but couldn’t stand (or do) chemistry.

    3. I had music and flute scholarships to college.

    4. I first decided to go to law school because I wanted to be an FBI agent.

    5. I crochet. A lot. It’s relaxing.

    6. I have two daughters: Isabella (71/2) and Hudson (31/2).

    7. My husband and I got married in the Center Township Small Claims Court at lunch one day.

    8. I once won a Motion for Summary Judgment based solely on the Rule Against Perpetuities. I still couldn’t explain it if I tried!

    9. My current assistant, Sue, was also my first assistant out of law school. I had to ask her what a “caption” was!

    10. I took 289 cases through the medi-cal review panel process at once.

    April Jay is scheduled to begin a trial for State Farm on February 2nd.

    Steve Couch is scheduled to begin a trial for State Farm on January 19th.

    Steve Bannwart is scheduled to begin a trial for State Farm on Jan-uary 20th.

    Christina Essex is scheduled to begin a trial for State Farm on Jan-uary 25th.

    Don Winningham is scheduled to begin a trial for State Farm on January 25th.

    four St. Jude House families in need.

    In addition to the charity drive, Mark Dolin donated the leftover food from the Michigan Holiday Party to the local Salvation Army. Sara Bowman delivered the food and expressed that they were extremely grateful for his generosity.

    Don Winningham is scheduled to begin a trial for Farm Bureau on February 2nd.

    Minh Wai is scheduled to begin a trial for Austgen Properties Inc. on January 29th.

    Deb Kapitan is scheduled to be-gin a trial for Philadelphia Insur-ance on January 27th.

    Christine Sutton is scheduled to begin a trial for State Farm on Jan-uary 25th.

    Michael Barey is scheduled to be-gin a trial for Sentry Insurance on January 8th.

    Brian King is scheduled to begin a trial for Farm Bureau on January 15th.

  • 11

    Our client, the City of Michigan City, was granted Summary Judgment by Chief Judge Simon of the U.S. District Court - Northern District of Indiana in racial discrimination claim after firing a transit employee for not stopping properly at a railroad cross-ing while driving a school bus. The Court agreed with our argument that the Plaintiff failed to prove that he was meeting his em-ployer’s legitimate expectations or that oth-ers similarly situated outside his protected class were treated more favorably. In the Court’s lengthy Opinion, the Judge com-mented on evolving opinions of the judg-es in the 7th Circuit that may change the long-standing complex tests involved in dis-crimination cases.

    Sheri Bradtke McNeil - PartnerCrown Point Office

    Recent Case Success

    Kevin M. Mulvaney - AssociateFarmington Hills Office

    Val H. Mock- Senior AttorneyFarmington Hills Office

    Val Mock was recently granted a summary judgment in Federal Court on a premises case involving a major convention center where the plaintiff broke his neck.

    On a separate case, a motion to set aside a two month default was granted on a brain injury case, and then the case subsequently dismissed.

    Kevin Mulvaney had a recent victory on a case where the Plaintiff, a police officer, was injured in the line of duty when a drunk driv-er t-boned his car. He suffered significant in-juries including a hip fracture and was in a wheelchair for weeks. During the course of litigation, Kevin and his team closely mon-itored social network sites maintained by the Plaintiff and was able to ascertain that the Plaintiff returned to work within three months and was back training for endurance races like the Tough Mudder and half mara-thons. Through a site that maintains athletes races and times, Kevin was able to prove that not only did the Plaintiff return to all his ac-tivities, he actually got faster. At the recent facilitation, Plaintiff refused to come down from a $300,000 demand and our client nev-

    Love it or hate it, winter is upon us. Please send us your favorite seasonal pictures of family (fur-family includ-ed) and friends making the best of the frosty conditions. Send to [email protected].

    Winter is Coming!

    Bo Murphey recently obtained a defense verdict on a State Farm auto case in Porter County. Our client admitted to talking on her cell phone at the time of the T-bone collision with the Plaintiff. Despite this ad-mission, liability was strongly contested due to evidence showing that the Plaintiff and the co-defendant were racing prior to the time both turned in front of the defendant. The Plaintiff suffered significant injuries to his left shoulder that required surgery, and maintained that he was stopped prior to the time of the collision. However, his story changed on the stand, likely because of data that had been recently downloaded from his vehicle showing he was traveling approximately 20 mph at the time of impact. During an adversarial cross examination, the Plaintiff had no choice but to explicit-ly admit that he lied. After five days of tri-al, Plaintiff ’s counsel asked for a verdict of $180,000.00. After only 30 minutes of delib-eration, the jury returned a verdict in favor of both defendants.

    Bo G. Murphey - AssociateCrown Point Office

    Don A. Winningham- AssociateFarmington Hills Office

    Don Winningham recently obtained a win in the Michigan Court of Appeals. The case was a Farm Bureau Insurance slip and fall claim in which the Plaintiff alleges to have fallen on her way into a market restroom, which may have been dark or wet (or both.) The Plaintiff never quite got her version of events in order. She claimed several injuries, including those to her knees and hands, which she further claimed affected her career as a fashion de-signer in Texas or Michigan; she kept chang-ing the story. Regardless, Don first success-fully won a Summary Disposition motion in the Wayne County Circuit Court case in front of Judge Brian Sullivan. The Plaintiff appealed, and the Court of Appeals upheld the dismissal. Unfortunately for the Plaintiff, her $15 million demand will not be paid.

    er budged from a settlement offer of $16,500. Although the Plaintiff presented with on-going vascular issues, the Judge granted the summary disposition dismissing Plaintiff ’s claim in its entirety.

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