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USLegal Pamphlet on Bifurcation Form

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in this particular case the defendant had denied some things I thought were fairly obvious so I go and take a deposition of the defendant and now I get to talk directly to the defendant and I say look I'm going to read you paragraph seven of the complaint and I want to ask you why you answered seven in your answer the way that you did the plain was hurt you answered deny why did you deny that the plff was hurt the plff was hurt why can't we agree on that the defendant goes oh no we can't totally was hurt I'm like hold on a second why did you write it like that then I've never seen this before I said did you talk to your lawyer about this how did this happened and she goes no we didn't talk there's no attorney client privilege in Communications if you had no Communications what I basically come to find out is that the defense lawyer hired by the insurance company filed this answer before he ever talked to his client and just denied

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