Category: Age Discrimination

How Lawsuits Can Help Solve Problems

One of the great things about living in America, is we have something called “the rule of law.”

So, just what is that?

Well, in the U.S., instead of having a king sitting on a throne, we believe “the law is king.” That means that we believe we are ruled by laws, not other men and women. “The rule of law.” It’s precious stuff, friends.

So, what does any of that have to do with lawsuits.

Well, it turns out, that people just living their daily lives, are going to have problems that come up in dealing with other people.

There’s two ways to solve problems having to do with money, property or your person, what we call “civil” problems.

One is something called “self help.” In other words, if your neighbor built a high fence and you don’t like it, self help is taking a saw and cutting it down without permission.

Only we learned a long time ago that self help causes all kinds of problems. If you don’t believe me, try cutting down your neighbor’s fence and report back to me what happens. No, just kidding. Don’t do that. Self-help isn’t really all that helpful.

The other way to solve civil problems is something called a civil justice system.

When someone wants to solve a problem using the civil justice system, they file papers asking for some kind of relief. That’s basically what a lawsuit is. Pretty simple, huh?

Now, there is plenty of debate these days about whether there are too many lawsuits, or too few, and all that kind of stuff that I know you hear about all the time.

But, the truth is, when you have a civil problem, it become real important to you that someone can help you solve that problem in the fairest, least expensive and quickest way.

Now, I’m not here to give you legal advice and there are differences in how courts work in each state and in the federal system. Still, spend a little time with me and I think I can tell you some things that you didn’t know before and, hopefully, will help you with whatever problem you need to fix.

 

Bill Daniels is a trial lawyer and shareholder with the law firm of DANIELS LAW in Sherman Oaks, CA.  A graduate of Loyola Law School of Los Angeles, he is a former member of the Consumer Attorneys Association of Los Angeles Board of Governors, a founding member of Loyola’s Civil Justice Program and a past president of the Encino Lawyers Association.  Since 2007, he has been named a Southern California “Super Lawyer” by Los Angeles Magazine.  Mr. Daniels focuses his practice on serious personal injury, insurance and employment. For information, visit our website at www.daniels.legal or contact us through e-mail: Info@danielslaw.com.

 

Defective Product Litigation and Injury Lawsuits

On the surface, product liability would seem to be a pretty cut and dry area of the law and being a litigation attorney may not seem super exciting. I mean it all seems like common sense. Some manufacturer or seller creates or distributes a product, a consumer purchases it and is injured, or perhaps even dies as a result of using it and naturally the manufacturer is automatically responsible for said injury and attempts to make things right. However, this area of law has many pitfalls that await consumers who have been harmed and for the inexperienced personal injury attorneys who try these cases.

Filing a Product Liability Lawsuit

According to some estimates, injuries, deaths and property damage from defective and recalled products cost the public more than $500 billion each year. Recently, a man in San Jose was awarded a $9.8 million judgment in a product liability case involving a surgical stapler that caused him grave bodily harm. Thus, product liability cases, unfortunately, are not an insignificant part of the legal system. In this case, without the proper legal counsel as to the circumstances, criteria and time limits involved in filing suit in a personal injury claim for product liability,it could have ended even more tragically for this person. Knowing when to file a case is one of the first steps to succeeding in personal injury cases involving product liability. In the state of California, for example, an action must be brought within two years from the time when the injury occurred. Here are some other things to know when filing a personal injury claim involving a defective product:

Establishing liability in personal injury cases involving a defective product

There are four legal means for establishing liability in personal injury cases involving a defective product:

  • Negligence: This is when expected, reasonable care is not taken and an obligation to do so exists. Negligence can occur when defective partsor improper assembly result in some injury.
  • Breach of Warranty: This is when a seller fails to uphold a claim or promise regarding their product.
  • False Advertising: This is when a consumer is misled into believing that a product is safer than it actually is.
  • Strict Liability: This is when the manufacturer or seller of a defective product is responsible for all injuries occurring from the use of the product. This also means that everyone involved in the making of a consumer product is potentially liable for any personal injury that results from using the product.

Obviously, manufacturers and sellers never mean to harm consumers with the products they create or distribute. However, intent is irrelevant when you suffer an injury and are required to pay hospital bills or when a loved one is struck down through no fault of his or her own. How can you be made whole after you are harmed by faulty—even deadly—products? We are Daniels Law, a Hollywood law firm that specializes in all areas of personal injury including the very complicated area of product liability. We are familiar with all aspects of product liability and can inform you as to your time limits to file and the types of product defects (design, manufacturing errors and false advertising) there are. We know that the cost to life and limb in these cases can be inestimable.

Bill Daniels is a trial lawyer and shareholder with the law firm of DANIELS LAW in Sherman Oaks, CA.  A graduate of Loyola Law School of Los Angeles, he is a former member of the Consumer Attorneys Association of Los Angeles Board of Governors, a founding member of Loyola’s Civil Justice Program and a past president of the Encino Lawyers Association.  Since 2007, he has been named a Southern California “Super Lawyer” by Los Angeles Magazine.  Mr. Daniels focuses his practice on serious personal injury, insurance and employment. For information, visit our website at www.daniels.legal or contact us through e-mail: Info@danielslaw.com.

Your rights as an employee in California

Obviously, your job is important to you. It feeds your family. It pays the rent. It helps to educate your children.

You work hard for your employer. You show up on time and stay late when needed. You do your best to succeed.You are a “company” worker.

Though you have to meet the requirements expected at work, you also have certain rights under the law as an employee. You have employee rights under California law.

For example, generally speaking, you employer has to pay you the minimum wage. Most hourly employees are also entitled to regular breaks, overtime pay, worker’s compensation insurance, unemployment insurance and unpaid time off for serious illness or a new baby.

Sexual harassment in the workplace is generally prohibited, as is discrimination based on certain characteristics such as gender, race, national origin or religion. If you suffer from a disability, your employer may be required to accommodate you by making changes in the workplace so your can perform the essential functions of your job position.

Sometimes a situation at work will seem unfair or even intolerable. When it does, it is best not to suffer in silence. Let your supervisor know that there is a problem, or if appropriate, consult with human resources. Most workplace problems can be resolved informally when there is communication. You may be surprised with the result! You may be surprised regarding how and why California law protects your employee rights.

If your employer is unwilling to help you solve your workplace problem, there may be other solutions. The California Department of Industrial Relations can help you understand your rights and provides services for employees in the state.  There are low-income clinics and workshops aimed to assist California workers, you can find references to them on the internet.

Of course, if you have a serious employment problem, whether its wage and hour, wrongful termination or discrimination, Daniels Law Offices is on your side.

 

Bill Daniels is a trial lawyer and shareholder with the law firm of DANIELS LAW in Sherman Oaks, CA.  A graduate of Loyola Law School of Los Angeles, he is a former member of the Consumer Attorneys Association of Los Angeles Board of Governors, a founding member of Loyola’s Civil Justice Program and a past president of the Encino Lawyers Association.  Since 2007, he has been named a Southern California “Super Lawyer” by Los Angeles Magazine.  Mr. Daniels focuses his practice on serious personal injury, insurance and employment. For information, visit our website at www.daniels.legal or contact us through e-mail: Info@danielslaw.com.

In California there are limits on what an employer can ask during a job interview

There are limits on what employers in California can ask you during a job interview, so it pays to know your rights.

In general, interview questions must relate to the background and skills that are necessary to perform the job in question.

Normally, your potential employer can’t ask questions about your age, religious beliefs or sexual orientation.  Also prohibited in most cases is asking whether or not you have, or once had, a disability, though the employer may ask if you are able to perform the general job duties for which you are being considered.

A potential employer usually is prohibited from asking if you’ve ever been arrested if the arrest did not lead to a plea bargain, verdict or some other finding of guilt. Employers are generally barred from obtaining your arrest record or from using an arrest alone in making employment decisions.  While there are exceptions to this rule (such as for certain law enforcement and other sensitive positions) this protection applies generally to both job applicants and employees seeking promotion.

Employers may ask if you have been arrested and are awaiting trial on criminal charges or, usually, if you have been convicted of a crime.  Still, there are protections for workers in this area as well.  So, an employer is usually barred from asking about any marijuana conviction more than two years old, or from inquiring about a conviction where the records were sealed.

 

Bill Daniels is a trial lawyer and shareholder with the law firm of DANIELS LAW in Sherman Oaks, CA.  A graduate of Loyola Law School of Los Angeles, he is a former member of the Consumer Attorneys Association of Los Angeles Board of Governors, a founding member of Loyola’s Civil Justice Program and a past president of the Encino Lawyers Association.  Since 2007, he has been named a Southern California “Super Lawyer” by Los Angeles Magazine.  Mr. Daniels focuses his practice on serious personal injury, insurance and employment. For information, visit our website at www.daniels.legal or contact us through e-mail: Info@danielslaw.com.

 

Your rights as an employee in California

Obviously your job is important to you. It feeds your family. Pays the rent. Helps educate your children.

You work hard for your employer. You show up on time and stay late when needed. You do your best to succeed.

Though you have to meet the requirements expected at work, you also have certain rights under the law as an employee.

For example, generally speaking, you employer has to pay you the minimum wage. Most hourly employees are also entitled to regular breaks, overtime pay, worker’s compensation insurance, unemployment insurance and unpaid time off for serious illness or a new baby.

Sexual harassment in the workplace is generally prohibited, as is discrimination based on certain characteristics such as gender, race, national origin or religion. If you suffer from a disability, your employer may be required to accommodate you by making changes in the workplace so your can perform the essential functions of your job position.

Sometimes a situation at work will seem unfair or even intolerable. When it does, it is best not to suffer in silence. Let your supervisor know that there is a problem, or if appropriate, consult with human resources. Most workplace problems can be resolved informally when there is communication. You may be surprised with the result!

If your employer is unwilling to help you solve your workplace problem, there may be other solutions. The California Department of Industrial Relations can help you understand your rights and provides services for employees in the state.  There are low-income clinics and workshops aimed to assist California workers, you can find references to them on the internet.

Of course, if you have a serious employment problem, whether its wage and hour, wrongful termination or discrimination, Daniels Legal | Law Offices is on your side.

Bill Daniels is a trial lawyer and shareholder with the law firm of DANIELS LAW in Sherman Oaks, CA.  A graduate of Loyola Law School of Los Angeles, he is a former member of the Consumer Attorneys Association of Los Angeles Board of Governors, a founding member of Loyola’s Civil Justice Program and a past president of the Encino Lawyers Association.  Since 2007, he has been named a Southern California “Super Lawyer” by Los Angeles Magazine.  Mr. Daniels focuses his practice on serious personal injury, insurance and employment. For information, visit our website at www.daniels.legal or contact us through e-mail: Info@danielslaw.com.

Due Process

Labor Code Section 203 provides a waiting time penalty that is consistent with constitutional due process.

State Farm v. Campbell (2003) 538 U.S. 408 concerns constitutional due process limits on punitive damages, not civil penalties.  As the Supreme Court notes, one prong of its test in BMW of North America, Inc. v. Gore (1996) 517 U.S. 559 (which refused to sustain a $2 million punitive damages award accompanying $4,000 in compensatory damages) is “the difference between the punitive damages awarded by the jury and the civil penalties authorized or imposed in comparable cases.”  The evil Campbell sought to remedy was the risk of an excessive punitive award imposed by a lay jury.  “We have admonished that ‘[p]unitive damages pose an acute danger of arbitrary deprivation of property.  Jury instructions typically leave the jury with wide discretion in choosing amounts, and the presentation of evidence of a defendant’s net worth creates the potential that juries will use their verdicts to express biases against big businesses, particularly those without strong local presences.”

The law does not view wage penalties as implicating property rights, which puts the 203 penalty outside of Campbell right at the start.

“A statute entitled ‘An act to provide for the protection of servants and employees of railroads,’ relating to the payment of unpaid wages without abatement or deduction on discharge of an employe[e], does not amount to deprivation of property, as the act is purely prospective in its operation.  It does not interfere with vested rights, existing contracts, or destroy, or sensibly encroach upon, the right to contract, although it imposes a duty in reference to the payment of wages actually earned, which restricts future contracts in the particular named.”  [Citation omitted.]

Moore v. Indian Spring Channel Gold Mining Co. (1918) 37 Cal.App. 370, 378 (quoting St. Louis, etc., R.R. Co. v. Paul, 173 U.S. 409).

When the section 203 penalty scheme withstood a constitutional due process challenge early in the last century in Moore v. Indian Sprint Channel Gold Mining Co. (1918) 37 Cal.App. 370, the remedial purpose of the penalty was highlighted in the decision.  After a penal statute imposing misdemeanor liability and a fine not to exceed five hundred dollars was ruled unconstitutional (Matter of Crane, 26 Cal.App. 22), the legislature changed the law to impose a penalty based on wages with a thirty day limit.

Appellant expresses difficulty in discovering any material distinction between the two acts.  In the act of 1911, continues the brief, the penalty is nothing more nor less than a fine not exceeding five hundred dollars; while in the amendment of 1915 the penalty is in effect a fine not exceeding thirty times the servant’s daily wage.”  It seems to us that the distinction is obvious in this:  The act of 1911 declares that a violation of its provisions is a crime for which the violator is answerable to the state, while by the amendment he must compensate the wage-earner by way of penalty.”

Moore at 373-374.  The court of appeal compared the penalty to other statutes, such as Code of Civil Procedure sections 732, 733 and 735 which impose treble damages on tenants who commit waste, cut down trees or forcibly detain property.  “The constitutionality of these sections is not questioned.  They are held not to be penal, but remedial.”  Id. at 375.

The Court of Appeal distinguished between remedial civil penalties and punitive damages in Los Angeles County Metropolitan Transportation Authority v. Superior Court (2004) 123 Cal.App.4th 261, and held that a government entity is not immune from civil penalties imposed by the Unruh Civil Rights Act (Civil Code section 52 et seq.) under Government Code section 818, which bars imposing punitive damages against public entities.  “[A] number of courts have concluded that to be condemned as punitive, a penalty, generally speaking, must simply and solely serve that purpose.”  Id.at  272  “It is apparent from this legislative history that section 52 has at least two important non-punitive purposes.  The first is simply to provide increased compensation to the plaintiff.  The second purpose, and perhaps the most important one, is to encourage private parties to seek redress through the civil justice system by making it more economically attractive for them to sue. . . . If not for the civil penalty, many such litigants would neither have the economic incentive nor the means to retain counsel to pursue perpetrators under the statute.”  Id. at 271-272.

Moore notes that the 203 penalty has a similar purpose.  “There has been a pronounced tendency in state and national legislation for many years, not only to ameliorate the working conditions of the wage earner, but to safeguard him in his relations to his employer in respect of hours of labor and the compensation to be paid for his labor. . .  the public safety and welfare demand . . . laws which are designed to secure [for labor] a reasonable wage, [and] to provid, where practicable, for the enforcement of payment by way of liens on the product of his labor . . . The intention of the penalty imposed by the act in question is to make it to the interest of the employer to keep faith with [its] employees and thus avoid injury to them and possible injury to the public at large.”  Id. at 381-382.

Note:  Moore repeatedly refers to the wage and labor laws under discussion as applicable to a class, e.g., “The act refers to all wage-earners, designated as employees, as the class referred to, and it unquestionably applies equally to all of the class.”  Id. at 379.

Bill Daniels is a trial lawyer and shareholder with the law firm of DANIELS LAW in Sherman Oaks, CA.  A graduate of Loyola Law School of Los Angeles, he is a former member of the Consumer Attorneys Association of Los Angeles Board of Governors, a founding member of Loyola’s Civil Justice Program and a past president of the Encino Lawyers Association.  Since 2007, he has been named a Southern California “Super Lawyer” by Los Angeles Magazine.  Mr. Daniels focuses his practice on serious personal injury, insurance and employment. For information, visit our website at www.daniels.legal or contact us through e-mail: Info@danielslaw.com.

Discovery and Depositions in the Bad Faith Case: What You Need to Know

Discovery and Depositions in the Bad Faith Case: What You Need to Know  

     Introduction

Insurance bad-faith cases are usually hard fought and can be bitter.

Generally speaking, when we take on a carrier for acting contrary to its insured’s interests and allege those actions are malicious justifying punitive damages, the folks on the defense side tend to take it personally.

So, the first rule of discovery in the bad faith case is, assume you are in for a tough fight. Which, in turn, leads to the second and third rules: know your adversary and be prepared.

The bad news that the general practitioner faces in prosecuting a bad faith case is that the defense team will usually be much better schooled in the fine points of insurance than an attorney who does not work with insurance matters on a daily basis.

The good news that the general practitioner can take heart from is B the purpose of bad faith law is to act as an equalizer between the powerful carriers who adjust claims for a living and the ordinary insured who probably never wanted to have a claim and, with luck, will never have another. Insurance regulations require that insurance companies keep a record of all material claims decisions. So, where there is wrongdoing, there is almost always a record of the bad acts waiting to be uncovered.

The key discovery strategy in defending bad faith cases is to deny the plaintiff information. However, if you know where and how to dig, it’s not that difficult to get the evidence you need to put on your successful case.

   Know your adversary

People spend their lives learning about the insurance business, which itself represents a huge, multifaceted, globally diverse industry devoted to making money by spreading risk. Generally, you do not have a lifetime to learn each and every nuance of the insurance world. So, don’t try. But do make sure you know everything you can about the facts and circumstances of the insurance business as it applies to your case.

Understand that the defendant or defendants in your prospective case may not be obvious from the face of the insurance materials your clients hand you. For example, it is not unusual to have a client provide letters on letterhead from the “Farmers Insurance Group of Companies.” Some practitioners will put this name in their complaint. Only, there is no such creature that can be sued. “Farmers Insurance Group of Companies” is simply the trade name for a collective of entities organized as inter-insurance exchanges. Usually, the proper defendants in a Farmers claims case are Farmers Group, Inc. (the management company), Farmers Insurance Exchange (the claims handling entity) and the insuring exchange (ie., Fire Insurance Exchange, Truck Insurance Exchange, etc.). See, Tran v. Farmers Group, Inc. (2002) 104 Cal.App.4th 1202 (rev. den. Mar. 26, 2003).

So, when laying out your case, always make sure you closely review the original insurance policy and declarations pages prior to determining who to name in your complaint. When in doubt, consult with experienced practitioners about who the proper parties are and why. Getting the defendants right at the beginning can save tremendous amounts of time during the case.

Also, make sure you understand who has standing to sue under the insurance policy. A business owner may not be able to sue for bad faith if the named insured is a corporation or limited liability company. On the other hand, the owner may have standing as an additional insured. The question is important where there is a potential for emotional distress and other general damage to the owner. Again, look to the policy and declarations pages for the answer.

 Getting to the Heart of Your Case in 60 days or less.

Once you have the parties clear in your mind and have filed suit, you can prepare your initial round of discovery for service once the defendants answer or, as is more typical, demur.

I seldom use interrogatories during my initial bad faith discovery. I find it is much more productive to immediately demand the claim file(s) and, if warranted, the underwriting file(s), since these are the basic documents necessary for preparing any bad faith case for trial.

Because these files are key evidence in the case, and in order to discourage potential mischief in discovery, I ask for the documents in multiple requests, simultaneously, using a formal request for production of documents, along with a custodian of records deposition notice and notice of deposition of the person most qualified. By utilizing this process, I find I am able to exert maximum pressure on the defense to produce the entire record all at once. This process also insures that I will be able to either establish foundation for the insurance files either by direct testimony or stipulation, so that they are admissible later in the case. Do not assume that a claim file or any other document will be admitted at trial under the business records exception to the hearsay rule. Nail down the foundation as you go, it will save much grief later on.

It is also important to make sure that the original files are available during any depositions. Copies of files don’t do the originals justice B often information about file handling can be gleaned from handwriting on the file folders themselves or how the files are organized. It is much easier for insurance adjusters and other key witnesses to evade answering key questions if the original files are not in front of them. Copies of file materials are okay as part of a document production and, in fact, are easier to handle as you organize your case. But make sure you request to see the originals and insist they be produced.

Person most qualified depositions under Code of Civil Procedure section 2025.220 are the fastest way to gain general information about the basic handling of the claim or other insurance matter that lies at the heart of your case. I typically notice the person most qualified to testify regarding the identities of each and every individual who performed work or made a decision in the matter. Generally, the witness will be the primary claims adjuster, which is fine. However, the PMQ deposition helps avoid wasting time meeting and conferring over boilerplate objections and incomplete responses typical when interrogatories are served.

Also, try to determine whether or not the defense will be allowing on advice of counsel as a defense by serving a simple Request for Admission that is on point. Carriers generally do not like using the defense since it opens up areas that would otherwise be privileged. But don’t assume it won’t be used. Ask up front.

I have number of sample deposition notices, discovery requests and requests for admissions that are regularly requested from me. If you’re interested, click here for the set. Please note, the forms I provide use the old Code of Civil Procedure sections, so you should update them before using them in your case

 Focusing Depositions

Once I know who was involved with the claim or other insurance matter I am concerned with, I typically depose everyone who touched the file in any way. Even if the deposition lasts only fifteen minutes, absent a stipulation, getting the testimony is the only way to insure that all the potential holes in your cases are filled.

I prefer to video all key depositions, particularly the adjusters and claims personnel. The best insurance bad faith cases are generally morality plays where the attitude and demeanor of the witnesses are just as important as their precise testimony. A picture, as the saying goes, is often worth a thousand words.

When deposing insurance professionals, I almost always begin by getting them to agree with me as to basic principles such as an insurance carrier must give its insured’s interests equal weight with its own,” an insurer is obligated to conduct a thorough, fair and objective investigation into the facts of a claim,” etc. Once I establish the common framework of duty, I use those basic principles to tie down the witness while going through the claim.

Lists of duties and obligations can be gleaned from the case law, jury instructions and your experts. Make one up that works for your case and use it from day one.

In deposing witnesses, utilize the insurance files you obtained at the beginning of the case as both a guide to questioning and evidentiary support for your case. Adjusters will have diary notes, these should be analyzed and authenticated by the witness. If it is unclear just what notes or materials were created by the witness, don’t be afraid to ask. Unraveling how a claim was handled is often like piecing together an intricate puzzle. Be thorough with each witness and you will not need to fear missing pieces when your discovery is concluded.

Also, just as in any case, don’t be afraid to lead adverse witnesses as allowed by Evidence Code section 776. Leading questions are the best way to focus an adverse witness, especially one that might be inclined to waste your time with irrelevant insurance technicalities and side issues.

   Conclusion

There’s no magic to conducting bad faith discovery. Just preparation, study and hard work.

While the basics outlined in this article should help you get going, don’t forget that there is a strong community of insurance bad faith practitioners available who can help answer particular questions or give guidance on technical issues.

In my mind, there is no nobler endeavor than fighting for deserving individuals who have been legitimately wronged by powerful institutions. Hopefully, you are of the same mind. So, go get ’em!

 

Bill Daniels is a trial lawyer and shareholder with the law firm of DANIELS LAW in Sherman Oaks, CA.  A graduate of Loyola Law School of Los Angeles, he is a former member of the Consumer Attorneys Association of Los Angeles Board of Governors, a founding member of Loyola’s Civil Justice Program and a past president of the Encino Lawyers Association.  Since 2007, he has been named a Southern California “Super Lawyer” by Los Angeles Magazine.  Mr. Daniels focuses his practice on serious personal injury, insurance and employment. For information, visit our website at www.daniels.legal or contact us through e-mail: Info@danielslaw.com.

CA Employment Discrimination and FEHA

In California, workers are protected from employment discrimination by law.

FEHA protects California workers from employment discrimination
Employment Discrimination laws in FEHA protect California workers

Some of the strongest employee protections are found “FEHA.”

The Fair Employment and Housing Act (FEHA) prohibits harassment and discrimination in employment because of race, color, religion, sex, gender, gender identity, gender expression, sexual orientation, marital status, national origin, ancestry, mental and physical disability, medical condition, age, pregnancy, denial of medical and family care leave, or pregnancy disability leave (Government Code sections 12940,12945, 12945.2) and/or retaliation for protesting illegal discrimination related to one of these categories. Continue reading “CA Employment Discrimination and FEHA”

Walmart Stores v. Dukes Transcript

The Supreme Court heard oral argument Tuesday on a challenge to the certification of a class-action lawsuit on behalf of female employees against the giant retailer Wal-Mart.

This is an important case.  We are all waiting to see how the Supreme Court treats class actions in the context of gender discrimination.

Click here to read the Supreme Court transcript.

Bill Daniels is a trial lawyer and shareholder with the law firm of DANIELS LAW in Sherman Oaks, CA.  A graduate of Loyola Law School of Los Angeles, he is a former member of the Consumer Attorneys Association of Los Angeles Board of Governors, a founding member of Loyola’s Civil Justice Program and a past president of the Encino Lawyers Association.  Since 2007, he has been named a Southern California “Super Lawyer” by Los Angeles Magazine.  Mr. Daniels focuses his practice on serious personal injury, insurance and employment. For information, visit our website at www.daniels.legal or contact us through e-mail: Info@danielslaw.com.