Where are your balls, Craig? I didn’t hire you to roll over like a beaten dog.
Sincerely,
Pamela Holmstrum
Claims Superintendent
Western States Insurance Co.
Craig D. SchaefferAttorney-at-Law3615 MontereyPalm Desert, CA
Ms. Pamela A. HolmstrumClaims SuperintendentWestern States Insurance Co. 801 Flower StreetLos Angeles, CA
24 July 1983
Dear Ms. Holmstrum,
Thank you for your letter of the 21st inst. and may I observe what a wonderful thing it is that the attorney-client privilege allows us to have such a frank and open exchange of views.
While I understand your reluctance to reward a criminal act such as arson with a policy limits payment, I would be remiss in my duty as your attorney not to advise you to nevertheless do just that.
You have no proof. You have no witnesses. If you deny this claim, Mr. Muller will most likely file a bad-faith lawsuit which could expose your company to a multimillion-dollar punitive-damages award.
Pamela, I know that you are new to this job and eager to impress your bosses and that at your tender age you nevertheless deserved this promotion. I am further sensitive to the fact that, as a young woman executive, you feel more than the usual pressure to show “toughness.” I understand these things. Nevertheless-and again-my best opinion is to pay the $600,000 now or risk having a very large, multilingual, singing simian indeed force its egress from your digestive system, the hard way.
Sincerely,
Craig Schaeffer, Esquire
By Fax
July 26, 1983
Dear Craig,
Too late. I denied both claims.
Pamela
By Fax
July 26, 1983
Dear Pamela,
He’ll sue.
Craig
By Fax
July 26, 1983
Dear Craig,
He doesn’t have the cajones.
Pam
The Law Offices of Eugene E. Petkovitch1500 Mitch Miller BoulevardPalm Springs, CA
Ms. Pamela Holmstrum
Western States Insurance Co.
801 Flower Street
Los Angeles, CA
27 July 1983
Dear Ms. Holmstrum,
This letter is to put you on notice that I have filed a lawsuit on behalf of my client and your insured, Mr. Heinz Muller, for breach of contract and bad faith. The conduct of both your claims department and its coverage counsel, Attorney Craig Schaeffer, has been despicable in the extreme. Your fraudulent, oppressive and malicious attempts to violate the rights of my client and avoid paying the insurance benefits to which he is rightly entitled are flagrant violations of both California law and common decency.
I am personally and professionally outraged-OUTRAGED-that an insurance carrier in this day and age would single out for oppressive treatment an individual just because that person happens to be a foreign immigrant. Immigration built this land, Ms. Holmstrum, lest you or Western States Insurance Company ever forget it!
Your conduct has been despicable!
I am certain that a California jury will send a message to the insurance industry-via a large punitive damages award-that this type of conduct will no longer be tolerated.
There is still time for you to avoid litigation.
My client, Mr. Heinz Muller, is generously willing to accept full policy benefits plus an additional $10,000,000 for the pain, suffering and humiliation that your Gestapo-like inquisition and jackboot investigative tactics have inflicted upon him. This sum represents far less than an outraged jury would award and saves you the cost of a long, expensive, and ultimately futile defense.
This offers expires at close of business, five working days hence, and will not be compromised or renewed.
Sincerely yours,
Eugene Petkovitch, Esquire
The Law Offices of Eugene E. Petkovitch1500 Mitch Miller BoulevardPalm Springs, CA
Ms. Pamela Holmstrum
Western States Insurance Co.
801 Flower Street
Los Angeles, CA
27 July 1983
Dear Ms. Holmstrum,
This letter is to put you on notice that I have filed a lawsuit on behalf of my client and your insured, Mr. Amin “Sami” Abdullah, for breach of contract and bad faith. The conduct of both your claims department and its coverage counsel, Attorney Craig Schaeffer, has been despicable in the extreme. Your fraudulent, oppressive and malicious attempts to violate the rights of my client and avoid paying the insurance benefits to which he is rightly entitled are flagrant violations of both California law and common decency.
I am personally and professionally outraged-OUTRAGED-that an insurance carrier in this day and age would single out for oppressive treatment an individual just because that person happens to be a foreign immigrant. Immigration built this land, Ms. Holmstrum, lest you or Western States Insurance Company ever forget it!
Your conduct has been despicable!
I am certain that a California jury will send a message to the insurance industry-via a large punitive damages award-that this type of conduct will no longer be tolerated.
There is still time for you to avoid litigation.
My client, Mr. Amin ‘Sami’ Abdullah, is generously willing to accept full policy benefits plus an additional $5,000,000 for the pain, suffering and humiliation that your Gestapo-like inquisition and jackboot investigative tactics have inflicted upon him. This sum represents far less than an outraged jury would award, and saves you the cost of a long, expensive, and ultimately futile defense.
This offers expires at close of business, five working days hence, and will not be compromised or renewed.
Sincerely yours,
Eugene Petkovitch, Esquire
Ms. Pamela A. HolmstrumClaims SuperintendentWestern States Insurance Co. 801 Flower StreetLos Angeles, CA
Craig D. Schaeffer
Attorney-at-Law
3615 Monterey
Palm Desert, CA
27 July 1983
Dear Craig,
Please see attached correspondence from Attorney Eugene Petkovitch on behalf of his clients, our policyholders, Heinz Muller and Amin “Sami” Abdullah.
FIFTEEN MILLION DOLLARS!!!???
He sends us form letters demanding fifteen million dollars?!
Who does this guy think he is?!
Pam
Craig D. SchaefferAttorney-at-Law3615 MontereyPalm Desert, CA
Ms. Pamela A. Holmstrum
Claims Superintendent
Western States Insurance Co.
801 Flower Street
Los Angeles, CA
29 July 1983
Dear Pam,
You’ve never heard of Eugene “The Wolverine” Petkovitch?! Where have you been?
Eugene Petkovitch is the most despised, loathed, feared and respected plaintiff attorney in California, if not the known litigious world. Over the past ten years the Wolverine has hit every major insurance carrier in the state for seven- and eight-figure punitive damages awards.
When that security guard in mid-Wilshire shot the big toe off the would-be bank robber and the bank robber got $2,000,000? Eugene “The Wolverine” Petkovitch.
When the security guard sued the company that made the gunsight and won $3,000,000? Eugene Petkovitch.
When the would-be bank robber sued his insurance company for failing to pay his legal costs, citing “Chronic Recidivist Syndrome” and won $5,000,000? Eugene Petkovitch.
When the security guard sued his insurance company, the bank’s insurance company, and the would-be robber’s insurance company, citing “Severe Post-Victimization Stress Disorder” and won $6,000,000? Eugene Petkovitch.
These are just a few of the judicial highlights of the Wolverine’s recent career.
The guy’s cross-examinations are brutal. I’ve seen them. I remember. I wish I could forget.
I’ve seen hardened insurance executives break down and sob on the stand during one of Gene’s cross-exams. I’ve seen homicide cops blubber like babies. I’ve seen guys develop permanent eye twitches and stutters. In fact, one of Gene’s victims was a claims superintendent who happened to be a deaf mute. Gene crossed him in sign language and I swear the guy’s hands were shaking. The jury concluded he was lying.