Bobby N. Harmon, CPCU, ARM
October 21, 2004
VIA fax only @ (406) 728-7416
Robert S. Tameler
Attorney Liability Protection Society
P.O. Box 9169
Missoula, MT 59807-9169
RE: HARMON v. TAMM & DUNN - Lawyers’ Professional Liability Claims
Ref. Prior ALPS Claim Numbers B023134 & B023235
Dear Mr. Tameler:
It has now been nearly 30 days since my letter to you dated September 28, 2004, in which I stated:
“This is to report new information which has become known as a result of the arbitration proceedings conducted in the case of Trustee Mary Lou Woo vs. Harmon.
“First, I refer you to Bradley R. Tamm’s facsimile dated April 6, 2002, addressed to Steven Guttman, Matt Tsukazaki and Susan Tius. In this communication, Bradley Tamm attached a copy of my letter to Gregory T. Dunn dated March 30, 2002, about which he stated:
“TRANSMITTED HEREWITH IS A COPY OF A LETTER RECENTLY RECEIVED FROM MR. HARMON. APPARENTLY, HE IS SENDING NEARLY IDENTICAL LETTERS TO ALL OF US.
“I WOULD REQUEST THAT MR. TSUKAZAKI RELEASE TO ME A COPY OF ANY SIMILAR LETTERS SENT TO HIM, MS. TIUS, OR BISHOP ESTATES. I BELIEVE WE SHOULD ALL COOPERATE IN EXCHANGING SUCH INFORMATION FOR OUR MUTUAL BENEFIT AND THE PRESERVATION OF OUR CARRIER’S INTERESTS.”
“Second, is information contained in the Declaration of Steven Guttman in Support of Claimant’s Request for Attorneys’ Fees and Costs, dated September 2, 2004. In this lengthy document, there are many entries pertaining to direct contacts between Steven Guttman, Bradley Tamm, and others who evidently have conspired to defraud the estate for their own personal gain.
“As examples, I refer you to the following entries in Steven Guttman’s time sheets:
04/09/03
SG STATUS CONFERENCE W/ ATTY TIUS; EMAIL W/ ATTY TSUKAZAKI RE MEDIATION STATUS
08/14/03
WI LTR TO ATTY TAMM
09/26/03
SG E-MAIL TO ATTY TAMM RE WITNESS LIST
10/14/03
SG REVIEW BNH LTR TO ROBERT TAMELER & ATTY LIABILITY PROTECTION SOCIETY
10/16/03
SG CONF. W/ATTY. TAMM RE ARBITRATION
SG TC FROM ATTY PETER OLSEN RE TAMM REPRESENTATION
10/17/03
SDF PREP FX TO P. OLSON RE CLAIM SUBMITTAL TO ARB & RESP WITNESS LIST.
10/22/03
SG REVIEW LTR FROM BNH RE ARBITRATION; WEB PAGE REVIEW COORDINATION; TC FROM ATTY TIUS RE ARBITRATION
11/06/03
SG TC FROM ATTY OLSON RE ARBITRATION /TAMM TESTIMONY
11/18/03
WI TCS WITH ATTY OLSON RE ARBITRATION
11/19/03
WI RVW LTR FROM ATTY OLSON & MEMO TO SG RE SAME
11/20/03
SG REVIEW LTR FROM ATTY OLSON RE TAMM TESTIMONY
12/12/03
WI RVW LTR RE ALLEGED WRONGDOING & MEMO TO SG
SG REVIEW BNH LTR RE CLAIM NOTICE.
04/30/04
WI COMPILE ENCLS & DRAFT LTR TO BRAD TAMM’S ATTORNEY
SG TC TO ATTY MT [MATT TSUKAZAKI] RE DIRECT WRITTEN TESTIMONY (L/M)
SG OUTLINE/REVIEW LTR TO ATTY OLSON RE TAMM TESTIMONY
05/03/04
WI RVS/FIN/PROCESS LTR TO ATTY TSUKAZAKI RE CASE STATUS
SG REVIEW LTR TO ATTY OLSON RE TAMM TESTIMONY; OUTLINE MTN LIMINE
SG TC W/ATTY MT RE WITNESSES.
05/10/04
SG TC FROM ATTY OLSON RE TAMM TESTIMONY
06/09/04
SG TCs W/ATTY OLSON RE TAMM TESTIMONY
SG TC FROM ATTY MT RE ARBITRATOR’S RULING
06/10/04
WI MEMO TO ATTY TAMM RE ARB DEMAND & WEBSITE DATA
SG TC TO BRAD TAMM RE ARBITRATION; TC W/ATTY TIUS RE ARBITRATION ISSUES
SG TC FROM ATTY OLSON RE TAMM TESTIMONY
06/11/04
SG MTG W/TAMM RE SUBPOENED TESTIMONY; REVIEW ARBITRATOR LTR RE ACCESS TO ARBITRATION
06/14/04
SG TC W/PETER OLSON RE TAMM TESTIMONY
06/18/04
WI MEMOS TO ATTYS MT & ST [SUSAN TIUS] RE ORDER & BH LTR
SG REVIEW MT E-MAIL RE BNH COMMUNICATIONS
06/21/04
WI RVW BH LTR RE CLAIM NOTICE
WI MEMOS TO ATTY MT & TRUSTEE RE BH DISPUTE LETTER
SG REVIEW ATTY MT E-MAIL RE BNH LTR
SG REVIEW BNH LTR RE CLAIM NOTICE
SG REVIEW BNH 13 PAGE LTR RE ARBITRATION ORDER
06/28/04
WI RVW ST MEMO TO ATTY MT RE INTERIM ORDER ENFORCE
06/29/04
WI MEMO TO ATTYS ST [SUSAN TIUS], MT [MATT TSUKAZAKI] & TRUSTEE RE 6/28 ORDER
SG TC W/ATTY TIUS RE ARBITRATOR ORDERS
SG E-MAIL TO ATTY MT RE ARBITRATOR ORDERS
07/08/04
SG TC TO ATTY MT RE STATUS
07/12/04
SG E-MAIL TO ATTY MT RE ARBITRATION DOCS
07/13/04
WI RVW ST & MT MEMOS RE ARB PLDGS
SG TC FROM ATTY MT RE FFICL.
SG TC FROM CLIENT RE STATUS; REVIEW PRICEWATERHOUSE LTR RE LEGAL COUNSEL
“Although the brief entries of Steven Guttman do not disclose what was discussed in these communications with my former attorney Bradley Tamm, I maintain that the fact there were direct, undisclosed contacts with him is a serious breach of ethics regarding attorney-client privilege, and clear evidence of collusion among the attorneys Bradley Tamm, Steven Guttman, Susan Tius and Matt Tsukazaki in this case.
“I have already indicated to certain other parties against whom I have separate outstanding claims, that I would be willing to attempt to negotiate a global settlement with all parties for all claims. I would be agreeable to including your insureds, Bradley Tamm and Greg Dunn, in these proposed global settlement negotiations. More information regarding these separate claims can be found at:
www.the-catbird-seat.net/Claims-By-Harmon.htm
“Please feel free to contact me if you have any questions or comments. Your prompt response to this letter will be appreciated.”
< END OF QUOTATION >
Due to the civil and criminal charges recently filed against Marsh & McLennan, Inc., Aon, Ace, St. Paul Travelers, and other insurance brokers and companies, for fraud and “kick-backs” of the type I have alleged in my claims letters, I would urge you to consider an attempt to negotiate a global settlement for all unresolved professional liability claims against you and your law firm.
I refer you to the following web addresses for additional information:
www.the-catbird-seat.net/Bishop.htm
www.the-catbird-seat.net/MarshBirds.htm
www.the-catbird-seat.net/Claims-By-Harmon.htm
www.the-catbird-seat.net/Aon.htm
www.the-catbird-seat.net/AIG.htm
www.the-catbird-seat.net/AlliedWorldAssurance.htm
www.the-catbird-seat.net/BuzzardsOfParadise.htm
www.the-catbird-seat.net/ChubbGroup.htm
www.the-catbird-seat.net/GoldmanSachs.htm
www.the-catbird-seat.net/Prudential.htm
www.the-catbird-seat.net/RICO.htm
www.the-catbird-seat.net/TheMeadows.htm
www.the-catbird-seat.net/Travelers-St-Paul.htm
Please advise me immediately if this proposal to negotiate an out-of-court global settlement is something that your insurance company wishes to consider as an alternative to further lawsuits involving these outstanding claims.
Thank you for your prompt response
Very truly yours,
Bobby N. Harmon, CPCU, ARM
References:
www.the-catbird-seat.net/BK-Objection-1-19-5.htm
www.the-catbird-seat.net/AAA-Dec-SG-re-fees.pdf
www.the-catbird-seat.net/AAA-Guttman-Att-A.pdf
www.the-catbird-seat.net/AAA-Guttman-Att-B.pdf
www.the-catbird-seat.net/AAA-Guttman-Att-C.pdf