PLAINTIFF ATTORNEY
We have no prior experience with plaintiff’s attorney, Carl H. Dreyer, Jr. Our brief research reveals that he is a solo-practitioner that was admitted to the Illinois bar in 2002. The majority of his practice is commercial litigation. We are unaware of any information that brings his competency into question.
SUMMARY OF CONVERSATIONS WITH PLAINTIFF COUNSEL
Initial Conversation:
We have reached out to plaintiff’s counsel and requested information relating to plaintiff’s alleged damages. We have also asked for a settlement demand in an effort to reach an early resolution. We have not yet received a response to these requests, but we will follow-up with the plaintiff’s attorney before discovery is initiated.
Follow Up Conversation(s): …show more content…
CRITICAL INVESTIGATION AND/OR DISCOVERY TO BE SCHEDULED/COMPLETED IN THE NEXT 60 DAYS IN ADVANCE OF EARLY NEGOTIATIONS OR MEDIATION
The insured’s answer is due on July 27, 2016. A case management conference is scheduled for August 3, 2016. At that conference, the Court will enter a scheduling order. We will file written discovery before the conference.
Discovery Item Projected Cost Anticipated Completion Date
Answer and affirmative defenses $1,500 July 27, 2016
Case management conference $ 200 August 3, 2016
Serve written discovery to Plaintiff $2,000 July 28, 2016
Respond to Plaintiff’s written discovery $4,000 September 1, 2016
EXPENSE AUTHORITY
Last Expense Authority Given By Examiner: $5,000
Date: June 13, 2016
Fees and Costs (Billed And/or Unbilled): $3,278.20
(Since the last expense authority above.)
Anticipated Cost Projection of Critical Investigation/Discovery Above: $12,500.00
NEW EXPENSE AUTHORITY REQUESTED: $12,500.00 to retain a consultant and participate in a site inspection.
COMMENTS/ADDITIONAL
We have no prior experience with plaintiff’s attorney, Carl H. Dreyer, Jr. Our brief research reveals that he is a solo-practitioner that was admitted to the Illinois bar in 2002. The majority of his practice is commercial litigation. We are unaware of any information that brings his competency into question.
SUMMARY OF CONVERSATIONS WITH PLAINTIFF COUNSEL
Initial Conversation:
We have reached out to plaintiff’s counsel and requested information relating to plaintiff’s alleged damages. We have also asked for a settlement demand in an effort to reach an early resolution. We have not yet received a response to these requests, but we will follow-up with the plaintiff’s attorney before discovery is initiated.
Follow Up Conversation(s): …show more content…
CRITICAL INVESTIGATION AND/OR DISCOVERY TO BE SCHEDULED/COMPLETED IN THE NEXT 60 DAYS IN ADVANCE OF EARLY NEGOTIATIONS OR MEDIATION
The insured’s answer is due on July 27, 2016. A case management conference is scheduled for August 3, 2016. At that conference, the Court will enter a scheduling order. We will file written discovery before the conference.
Discovery Item Projected Cost Anticipated Completion Date
Answer and affirmative defenses $1,500 July 27, 2016
Case management conference $ 200 August 3, 2016
Serve written discovery to Plaintiff $2,000 July 28, 2016
Respond to Plaintiff’s written discovery $4,000 September 1, 2016
EXPENSE AUTHORITY
Last Expense Authority Given By Examiner: $5,000
Date: June 13, 2016
Fees and Costs (Billed And/or Unbilled): $3,278.20
(Since the last expense authority above.)
Anticipated Cost Projection of Critical Investigation/Discovery Above: $12,500.00
NEW EXPENSE AUTHORITY REQUESTED: $12,500.00 to retain a consultant and participate in a site inspection.
COMMENTS/ADDITIONAL