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Jonah's versus national life good afternoon your honors may it please the court my name is Ethan Leonard along with Neil Brickman we represent the plaintiff appellant Stan Jonah's maxium management in this matter although it's this has remembered it's a pre answer a motion to dismiss phase this has been going on a long time this case but the issue before this court today is actually relatively simple with regard to a statute of limitations issue the fact is that my client mr. Jonas did not receive a breach of could not receive any contract that had any statute of limitations provision within it the record is clear that the only document mr. Jonas actually received appears at 294 of the record that is the certificate of insurance and has no reflection of any statute of limitation whatsoever within it now that on its own at a motion to dismiss stage makes it pretty clear the court will look at it it's a prior decision of this court rhubarb rhubarb fashion's Ltd versus Liberty Mutual poli

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