Free Memorandum - District Court of Arizona - Arizona

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[INSURANCE BAD FAITH]
In consideration of the legal services to be rendered by the law oflice of DAWSON &
ROSENTHAL, P.C. (hereinafter "ATTORNEYS") for any claims that I,
Kt €.‘H"'I>. LQQV-Q? (hereinafter "CLIENT") may have against the parties responsible for
- injuries and/or damages sustained by me as a result of bad faith acts of
pf ov? L ZL; gg AC; ['A 00*-Ir regarding health insurance benefits, I agree as follows:
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FEES
The CLIENT does employ said ATTORNEYS to comrnence and prosecute such claims,
and agree to pay said ATTORNEYS the following fees, and assigns to said ATTORNEYS a lien
in the following amounts:
FORTY PERCENT (40%) of any amounts recovered by settlement or judgment.
If this case is appealed by the other party, the 40% contingent fee referred to above _
increases to FORTY—FIVE PERCENT (45%). If CLIENT and ATTORNEYS agree that an
appeal should be pursued in this matter, then the attomey's contingent fee is subject to further I
negotiation.
If no recovery is obtained, no fee shall be payable to the ATTORNEYS.
NO REPRESENTATION HAS BEEN MADE AS TO WHAT AMOUNT, 11* ANY,
CLIENT MAY BE ENTITLED TO RECOVER IN THIS CASE.
LITIGATION COSTS
A All necessary costs and expenses incurred in said litigation shall be borne and paid by the
CLIENT. CLIENT agrees to pay the ATTORNEYS, the monthly sum of $@10 be held and
maintained in a trust account and applied toward litigation costs in the case. (Said payment to be
madepayable to "DAWSON & ROSENTHAL, P.C., Trust Account.") The ATTORNEYS agree A
to account periodically to the CLIENT as to all costs incurred and disbursed. All costs and .
expenses incurred in the handling of the case, over and above those reimbursed from CLIENT'S
monthly deposit, will be paid out of CLIENTS share of any settlement or recovery made.
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Case 2:02—cv—02281-SIVIIVI Document 263-3 Filed 12/22/2005 Page 1 of 2

MEDICAL EXPENSES
All medical expenses and charges of any nature made by doctors in conjunction with the
above-mentioned claim are not litigation costs and will be paid by the CLIENT. In the event of a
recovery, CLIENT agrees that the ATTORNEYS may pay any of these unpaid bills from
CLIENT‘S share of the recovery. Should CLIENT recover nothing, CLIENT understands that
the ATTORNEYS are not bound to pay any of these medical bills.
ASSOCIATE COUNSEL
Associate counsel may be employed at the discretion and expense of the ATTORNEYS.
CLIENT acknowledges and agrees that he is retaining the law ofiice of DAWSON &
ROSENTHAL, and that any of the trial lawyers in that firm may be handling or trying the case.
COMPROMISE OF SUIT
CLIENT agrees not to compromise his suit without full discussion with ATTORNEYS,
and the ATTORNEYS are not authorized to do so without client's consent.
APPEARANCES AND COOPERATION
CLIENT agree to keep said law office advised of my address and phone numbers at all ·
times, and to cooperate in the preparation and trial of my case; to appear on reasonable notice for
depositions and court appearances, and to comply with all reasonable requests made of me in
connection with the preparation and presentation of my case.
AUTHORIZATIONS
CLIENT hereby authorizes the law office of DAWSON & ROSENTHAL to tum over all
information, including doctor's reports, hospital records, etc., and any and all pictures to the
insurance company or to its attorneys.
DATED: xg H Ol- ’
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"£¤*·u.I/I » ‘ A
ACCEPTED AND APPROVED;

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Case 2:02-cv-02281-SMM

Document 263-3

Filed 12/22/2005

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Case 2:02-cv-02281-SMM

Document 263-3

Filed 12/22/2005

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