/TT1 40 0 R /CreationDate (D:20211201160919-06'00') /Resources << /Name /ZaDb 4 0 obj /Rotate 0 29 0 obj /Parent 12 0 R /TT0 39 0 R If you know of any Clinical Care Reviewers, Concurrent Review Nurses, Prior Authorization Nurses, or others that worked in a similar position who may be interested in making a claim for unpaid overtime, please inform them that they should contact the case clerk, Madeline Orozco, at (612) 256-3297 or morozco@nka.com com to determine whether they may be eligible to make a claim. /Type /Encoding xZl^ @o{%k /Parent 11 0 R Please ensure you do not destroy any documents or data you have that relate in any way to your work for AmeriHealth. /Resources << /Fields [] Iowa shifted its $4 billion Medicaid program to private management last year. AmeriHealth Caritas Louisiana has collaborated with the March of Dimes to offer Dismantling Bias in Maternal and Infant Healthcare provider training, and this training can now be accessed through the eLearning Module. Disability Rights Iowa officials on Friday said its group is evaluating its next steps. Try our Advanced Search for more refined results, Searching cases in Amerihealth Caritas >> Pa. Jan. 20, 2023). /Type /Page /Parent 11 0 R >> 11 0 obj 12 0 obj endobj Its sole named defendant is now Jerry Foxhoven, who succeeded Palmer as department director in June. /TT1 40 0 R %PDF-1.6 Win Toss Of SAG-AFTRA's Royalties Suit For Now, NLRB Should Keep Ballots Impounded, Transport Co. Says, 4th Circ. /MarkInfo << endstream . /TT2 41 0 R endobj Daily and real-time news and case alerts on organizations, industries, and customized search queries. /TT1 40 0 R to us until such time as an attorney-client relationship has been established. Today, the Federal Judge entered a stipulated Order "conditionally certifying" this lawsuit as a "collective action." /MediaBox [0.0 0.0 612.0 792.0] /Type /Page Multiple bills have been introduced in this years legislative session to change some of the ways Medicaid is managed, some that call for the state to again manage the program. /Contents [69 0 R 70 0 R 71 0 R] Subscribe to Justia's Free Newsletters featuring summaries of federal and state court opinions. Copies of the removal papers are available below. >> Lawyers for the group later changed the suit. /Type /Catalog AMERIHEALTH CARITAS . /CropBox [0.0 0.0 612.0 792.0] /TT0 39 0 R Claims may be keyed into the ConnectCenter within the AmeriHealth Caritas NaviNet provider portal using the 1500 and UB-04 online claim forms or submitted into the system by using the claim upload functionality. Kim Reynolds, say the shift is saving the state millions of dollars while leading to more efficient care for the approximately 600,000 poor or disabled Iowans who use the Medicaid program. No, you will not have to pay us anything out of your own pocket. The departure of a controversial Medicaid management company should block a federal lawsuit against Iowas human-services director, state lawyers say. COLLECTIVE ACTION . 2023, Portfolio Media, Inc. | About | Contact Us | Legal Jobs | Advertise with Law360 | Careers at Law360 | Terms | Privacy Policy | Cookie Settings | Help | Site Map, AmeriHealth Workers' $4.3M FLSA Overtime Deal Gets OK'd. (md, ). /TT0 39 0 R AmeriHealth Caritas is a multi-line health insurance company that provides managed care programs and related services. /Font << /Annots [] >> Disclaimer: Justia Dockets & Filings provides public litigation records from the federal appellate and district courts. >> /Tabs /S /CropBox [0.0 0.0 612.0 792.0] Disability Rights Iowa called several witnesses to testify about the effects of cuts in services paid for by Medicaid. >> << /Font << Arthur J. Tarnow, Senior United States District Judge. They are to be shifted to UnitedHealthcare or Amerigroup at the end of this month. endobj /TT1 40 0 R This is a collective and class action brought byindividual and representative Plaintiff Ann Wood ("Plaintiff"), on behalf of herself and ll others similarly situated,a to recover . x+ |
/Encoding 7 0 R /T1_0 94 0 R You may be eligible to make a claim under federal law if you worked over forty (40) hours per week for AmeriHealth within the past three years as a Clinical Care Reviewer, Concurrent Review Nurse, Prior Authorization Nurse, or in a similar position, and you were paid a salary. 28 0 obj Read full Disclaimer. /CropBox [0.0 0.0 612.0 792.0] >> On November 30, 2021, an AmeriHealth Caritas Services, LLC (AmeriHealth) employee filed a lawsuit in the United States District Court for the Eastern District of Pennsylvania to recover unpaid overtime wages from her employer. /Contents [57 0 R 58 0 R 59 0 R] >> /Length 492 23 0 obj /Contents [82 0 R 83 0 R 84 0 R] … He knows whos around him. If AmeriHealth did not keep accurate time records, most courts will permit you to make a good faith estimate of your work hours. . /Type /Page /Resources << /Resources << /Fm0 96 0 R /Annots [] In the Complaint, the Plaintiff alleges that AmeriHealth Caritas misclassified her and other Clinical Care Reviewers as exempt employees, denying them overtime compensation. >> SRt@)&Y The Settlement Administrator distributed FLSA Notices and Rule 23 Notices that informed Participating Settlement Class Members that the final approval hearing would take place on April 2, 2020 . /Fm4 100 0 R /MediaBox [0.0 0.0 612.0 792.0] /TT1 40 0 R << Copies of both of these Orders can be found below. 14 0 obj Use the links below to access additional information about this case on the US Court's PACER system. << /Count 7 RFP^ls)(QQd@6Ec\RRI
90uG /Font << Wargo said she brought Siegelhome after he was abused in a care facility. /Fm2 98 0 R Providers may also submit claims via the AmeriHealth Caritas NaviNet Provider Portal. 9 0 obj /ProcSet [/PDF /Text] >> A copy of the Answer is available below. The Judge overseeing this case is JAN E. DUBOIS. As This form will be filed with the Court. /ADBE_FillSignInfo << >> Plaintiff brings her overtime claims as a collective action under the federal Fair Labor Standards Act and as a class action under Pennsylvania state wage and hour law. /Kids [13 0 R 14 0 R 15 0 R 16 0 R 17 0 R 18 0 R 19 0 R 20 0 R] Mother says Iowas privatized Medicaid is unsafe for her son. Marilyn Doocys son Marty Matteson has Down syndrome and lives in his own home with assistance paid for by Medicaid. PLEASE NOTE: A verification email will be sent to your address before you can access your trial. Despite the sharp criticism and concerns voiced publicly by lawmakers in both parties, DHS Director Jerry Foxhoven has given the agency and the private companies' overseeingMedicaid high marks. /Fm5 101 0 R Read more here: Camp Lejeune Lawsuit Claims. In Travel Pay Row. Because we are in the early stages of the case, this has not happened yet, but we intend to seek the companys agreement or file the motions at the appropriate time asking the Court to grant these certifications. stream
The plaintiffs want U.S. District Judge Rebecca Goodgame Ebinger to order Foxhoven to step in and change the way the managed-care companies handle services for Iowans with disabilities. The lawsuit was filed in June on behalf of six Iowans with disabilities, who argue that the states shift to private management of Medicaid led to illegal cuts to their in-home care services. Iowans have publicly expressed outrage over denied care at multiple public events since the companies took over, pointing blame at each of the three companies. /ordmasculine 188 /onequarter /onehalf /threequarters 192 /Agrave /Aacute /Acircumflex /Atilde endstream /OCProperties << /Oslash /Ugrave /Uacute /Ucircumflex /Udieresis /Yacute /Thorn /germandbls /agrave /aacute /Rotate 0 endobj /Annots [] << . We are handling this case on a contingency basis. /F1 38 0 R If you have records relating to your work with AmeriHealth, please keep them until we ask you for them. If you would like additional information, please call our office at (215) 866-1551. /brokenbar 168 /dieresis /copyright /ordfeminine 172 /logicalnot /.notdef /registered /macron /C2_0 50 0 R Law360 takes your privacy seriously. >> 2 0 obj /quoteright /quotesinglbase /trademark /fi /fl /Lslash /OE /Scaron /Ydieresis /Zcaron ORDER GRANTING IN PART AND DENYING IN PART DEFENDANTS' MOTION TO SUMMARY JUDGMENT [43] Arthur J. Tarnow, Senior United States District Judge. /Resources << << Goodgame Ebinger recently presided over a daylong hearing on the suit that at times became emotional. The Disability Rights Iowa lawsuit was originally filed against Reynolds and Charles Palmer, who was then director of the Iowa Department of Human Services. << >> /Subtype /Type1 >> >> No. endobj /ProcSet [/PDF /Text] >> /Contents [43 0 R 44 0 R 45 0 R] >> AmeriHealth Caritas Services, LLC is on the receiving end of a proposed class and collective action filed by a current employee who claims she does not receive proper overtime wages. /Parent 11 0 R CARE IS doing the most you can to help people. /ProcSet [/PDF /Text] 6 0 obj endobj may be available from PACER. endobj /Parent 12 0 R Access this case on the Pennsylvania Eastern District Court's Electronic Court Filings (ECF) System. Iowas shift to privatized Medicaid is making changes that could leave Matteson without a safe option for staying in his home. One of them was Melinda Fisher of Cedar Rapids, who has a severe form of multiple sclerosis. /MediaBox [0.0 0.0 612.0 792.0] Thats an ideal world, she told the judge. A copy of the Complaint is available below. I would be forced to go into a nursing home, because I cant function on two hours a day, she said. endobj Our mission is to help people get care, stay well, and build healthy communities. /C2_1 93 0 R A lawsuit accusing Iowas privately run Medicaid program of illegally denying health assistance for thousands of Iowans with disabilities was dismissed Friday by a federal judge because the managed-care company in the suit ended its contract with the state. /F1 38 0 R There is a time limit under the federal law called a statute of limitations that allows an employee to recover unpaid wages for hours worked within two years of joining by filing a consent form. Critics say the change has led to red tape and arbitrary cuts in services, especially for people with disabilities. 30m
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Eligible individuals have until May 31, 2022 to join the case. /Font << /CropBox [0.0 0.0 612.0 792.0] To: AmeriHealth Caritas Louisiana Providers Date: October 11, 2021 Subject: Pending Lawsuit: A.A. et al. stream
If you have questions about your benefits, please call Member Services at 1-888-991-7200 or TTY 1-888-987-5704. %PDF-1.5
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17 0 obj >> Already a subscriber? /Type /Font This means we will only be paid if the lawsuit is successful in obtaining relief either through a settlement or an award, and that payment will only come out of that settlement or award. % LUMA v. AMERIHEALTH CARITAS, Court Case No. /MediaBox [0.0 0.0 612.0 792.0] /Pages 5 0 R /Fm3 99 0 R )p>:\?QdAD%iB-`6DA\(( AMERIHEALTH CARITAS Labor: Fair Standards Stay ahead of the curve In the legal profession, information is the key to success. Defendant (s) AmeriHealth Caritas Services, LLC Law (s) March of Dimes Awareness to Action: Dismantling Bias in Maternal and Infant Health Care How to Access Your eLearning Module. /Icircumflex /Idieresis /Eth /Ntilde /Ograve /Oacute /Ocircumflex /Otilde /Odieresis /multiply /Type /Page /BaseFont /Helvetica If you worked as a CHC Service Coordinator after April 1, 2019 and have not received the Notice and Consent Forms (because, for example, you recently moved), you should call us at (215) 866-1551. 9?TBP+074zt72*CnFIs:!,bE2|Hu@Mn!W' Tv+. << /acircumflex /atilde /adieresis /aring /ae /ccedilla /egrave /eacute /ecircumflex /edieresis AmeriHealth Caritas is a multi-line health insurance company that provides managed care programs and related services. You should consult an attorney for SERVICES, LLC, Defendant. /Resources << The list is updated frequently, so check . Your answers can help make sure you get the best care and service from us. Please see our Privacy Policy. /C2_0 50 0 R /ProcSet [/PDF /Text] From locally-focused health insurance plans to national-scale programs that assist those who need it the most, we exceed our customers' expectations through innovative health insurance and wellness solutions. The lawsuit is being spearheaded by the advocacy group Disability Rights Iowa, which has asked a federal judge to declare the suit a class-action case on behalf of about 15,000 Iowans with . /Parent 5 0 R Full-text searches on all patent complaints in federal courts. It doesnt matter which company youve got, theyre all profit-motivated and acting the same, Doocy said. He has for years lived independently through a network of assistance that his mother, Marilyn Doocy, said has saved her son from being institutionalized. New cases and investigations, settlement deadlines, and news straight to your inbox. /DA (/Helv 0 Tf 0 g ) /Rotate 0 /Name /Helv Won't Rethink Ruling Backing NC Farm Labor Law, NLRB Says Event Co. Must Assign Work To Teamsters, Replacement Steelworkers Win Class Cert. /Parent 11 0 R /Differences [24 /breve /caron /circumflex /dotaccent /hungarumlaut /ogonek /ring /tilde 39 >> /Annots [] << Later in the hearing, Assistant Attorney General Gretchen Kraemer tried to cast doubt on Wargos contention that all the in-home services her boyfriend receives under Medicaid are crucial to his health. /Producer <6954657874AE20372E312E3620A9323030302D323031392069546578742047726F7570204E56202841646D696E697374726174697665204F6666696365206F662074686520556E697465642053746174657320436F757274733B206C6963656E7365642076657273696F6E293B206D6F646966696564207573696E67206954657874AE20372E312E3620A9323030302D323031392069546578742047726F7570204E56202841646D696E697374726174697665204F6666696365206F662074686520556E697465642053746174657320436F757274733B206C6963656E7365642076657273696F6E29> endobj Click here to login, Enter your details below and select your area(s) of interest to stay ahead of the curve and receive Law360's daily newsletters, Email (NOTE: Free email domains not supported). /Type /Page /TT1 41 0 R /Rotate 0 /MediaBox [0 0 612 792] Before commenting, please review our comment policy. Doocy says voters this fall should take careful note of their representatives actions in the matter. /ModDate (D:20211202101246-05'00') << /CropBox [0.0 0.0 612.0 792.0] Law360 provides the intelligence you need to remain an expert and beat the competition. endobj That's why we offer a variety of benefits, services, and tools that focus on the whole person. … A showing that unconstitutional practices have taken place in the past is not enough. A copy of the Amended Complaint is available below. But lawyers from the Iowa attorney generals office contend the ground crumbled from beneath the lawsuit last week, when the management firm AmeriHealth Caritas announced it would withdraw from Iowas Medicaid program because of a contract dispute. /Parent 12 0 R E-MAILED To: COUNSEL on 9/9/2020 (bw, ), DEMAND for Trial by Jury by Tara L. Webb-Jones. /Count 8 Defendant AmeriHealth Caritas ("AmeriHealth Caritas" or "Defendant") is a foreign limited liability company with its principal place of business located at 200 Stevens Drive, Philadelphia, Pennsylvania 19113 12. /MediaBox [0.0 0.0 612.0 792.0] /Subtype /Type1 ORDER THAT THE ABOVE ACTION IS DISMISSED WITH . /Type /Font /MediaBox [0 0 612 792] The company's mission is to help those most in need get care, stay well, and build healthy communities. That left Amerigroup and UnitedHealthcare to manage claims for the 600,000 Iowans in the program. /Annots [] For help enrolling, you can call Healthy Louisiana at 1-855-229-6848 (TTY 711). We have decided that we are not going to challenge AmeriHealth Caritas' removal of this lawsuit to the United States District Court. >> So this lawsuit will go forward in the District Court and has been assigned to Judge Wendy Beetlestone. /Annots [] /Type /Page /Parent 12 0 R /CropBox [0 0 612.0 792.0] /Marked false /ProcSet [/PDF /Text] /dotlessi /lslash /oe /scaron /zcaron 160 /Euro 164 /currency 166 30 0 obj AmeriHealth Caritas Serving the Greater Philadelphia Area and Beyond This collective action lawsuit is going forward in the District Court for the Eastern District of Pennsylvania. /Resources << As she testified, Siegel sat in his wheelchair in the back of the courtroom, being comforted by supporters. Direct access to case information and documents. AmeriHealth Caritas Services, LLC Filed: August 15, 2017 2:17-cv-03697-GJP Read Complaint AmeriHealth Caritas Services, LLC is on the receiving end of a proposed class and collective action filed by a current employee who claims she does not receive proper overtime wages. /C2_0 50 0 R Although the process and terminology may differ slightly, the idea behind both a class and collective action is the same: it allows one or more people to sue on behalf of themselves and other similarly situated people who have similar claims. Case 2:17-cv-03697-GJP Document 1 Filed 08/15/17 Page 3 of 14 PARTIES 11. 2Q0`caInp V#I*bv00Vb D 2E01v`eX\3d)x``A8l3FPAA This browser does not support PDFs. >> /Rotate 0 endobj HRmo0X*TU$:m4JMS4)sg'
K[; /Version 100 Law360 may contact you in your professional capacity with information about our other products, services and events that we believe may be of interest.Youll be able to update your communication preferences via the unsubscribe link provided within our communications.We take your privacy seriously. /Resources << /degree /plusminus /twosuperior /threesuperior /acute /mu 183 /periodcentered /cedilla /onesuperior >> >> << /MediaBox [0.0 0.0 612.0 792.0] endobj /ProcSet [/PDF /Text] 21 0 obj Regardless of which managed care company is in place, the director of the Iowa Department of Human Services is ultimately responsible for ensuring that Iowans have the Medicaid services they need and receive notice and an opportunity for a fair hearing when their services are denied or cut.. Our attorneys are zealous advocates committed to fighting for the justice our clients deserve. /TT0 95 0 R A more recent docket listing /CS0 [/Indexed /DeviceRGB 59 90 0 R] Hes safe. Last Friday, April 15, 2022, our office sent court-approved notice of the lawsuit to all eligible individuals who have not already joined. /Rotate 0 >> /XObject << /D << /ProcSet [/PDF /Text] /Type /Page /Font << Do I Have a Qualifying Federal Law Claim? endobj /CropBox [0.0 0.0 612.0 792.0] Webb-Jones v. AmeriHealth Caritas Services, LLC, US District Court for the Eastern District of Pennsylvania, Summons Issued as to AmeriHealth Caritas Services, LLC. /GS0 85 0 R endobj /Type /Page /Rotate 0 >> >> On November 30, 2021, an AmeriHealth Caritas Services, LLC ("AmeriHealth") employee filed a lawsuit in the United States District Court for the Eastern District of Pennsylvania to recover unpaid overtime wages from her employer. >> In the legal profession, information is the key to success. We are proud of the work we did in Iowa and the accomplishments of our associates," Brett said. >> Please see our Privacy Policy. /Order [] action as a class action claim under Federal Rule of Civil Procedure 23. You have to know what's happening with clients, competitors,. /C2_0 50 0 R /Annots [] Class Action Settlement Recap Enhancements to Claim Payment Policy, Processing and Payment Disclosure, and an Appeals Process for Class Action Settlement Providers The following enhancements are effective for providers who agreed to the terms of the court-approved class action settlement ("Settlement Providers"), for Gregg v. AmeriHealth et al, Reflects complaints, answers, motions, orders and trial notes entered from Jan. 1, 2011.Additional or older documents may be available in Pacer. >> >> AMERIHEALTH CARITAS SERVICES, LLC et al Case Summary On 08/26/2020 LOCKE filed a Civil Right - Employment Disability Discrimination lawsuit against AMERIHEALTH CARITAS SERVICES, LLC. /Parent 11 0 R /TT0 39 0 R >> Already a subscriber? >> /Annots [] /Annots [] >> /TT1 40 0 R /ExtGState << /Contents [54 0 R 55 0 R 56 0 R] x. 15 0 obj /C2_0 86 0 R >> This takes the place of all previous print or website versions of the handbook. /Resources << endobj /Subtype /XML The plaintiffs say without those services, they could be forced to move into nursing homes, violating their constitutional rights. 7 0 obj Try our Advanced Search for more refined results. >> The workers allege that AmeriHealth Caritas violated Pennsylvania and federal law by failing to pay them full overtime premium compensation for hours worked over 40 per week. /CropBox [0.0 0.0 612.0 792.0] /Adieresis /Aring /AE /Ccedilla /Egrave /Eacute /Ecircumflex /Edieresis /Igrave /Iacute /Contents [63 0 R 64 0 R 65 0 R] See below for more details on this process. /Parent 12 0 R /MediaBox [0.0 0.0 612.0 792.0] >> Federal District Judge Rebecca Goodgame Ebinger on Friday issued a ruling that concurred with the states argument that there is no evidence in the record that the issues complained of by the plaintiffs relate to other managed care organizations.. /Name (Adobe Fill & Sign) >> >> advice regarding your individual situation. >> /F1 38 0 R >> /RBGroups [] 5 0 obj To join others in making a claim for overtime compensation under federal law, you must complete aPlaintiff Consent form. New to ClassAction.org? /TT2 41 0 R The deadline for individuals to join the lawsuit is May 6, 2022. 19 0 obj /TT0 39 0 R LUMA v. AMERIHEALTH CARITAS Federal Civil Lawsuit Pennsylvania Eastern District Court, Case No. /Parent 12 0 R /Tabs /S /TT1 41 0 R stream
/Contents [73 0 R 74 0 R 75 0 R] /ZaDb 10 0 R /ProcSet [/PDF /Text] Kim Reynolds said while mistakes have been made in implementing the new management systems,she doesnt believe the state should resume management of the program. /Im0 102 0 R )Z9h/c Though the plaintiff and similarly situated employees regularly work more than 40 hours per week, according to the complaint, they allegedly do not receive any time-and-a-half overtime wages for the hours they work above 40. Currently, we are working on a plan for completing "discovery," which is the phase of litigation where the parties exchange information and documents. We will seek any records the company has of your hours worked. /Tabs /S << >> /BaseFont /Courier Supporters, including Gov. LLC, 2023 U.S. Dist. >> >> Plaintiffs must show that such practices are likely to affect them in the future. The state lawyers asked the judge to deny the plaintiffs' requests for an injunction and a class-action declaration. More than 300clinical care review workers for AmeriHealth Caritas Services LLC secured approval from afederal judge Tuesday to finalize their $4.25 million settlement resolving a collective action alleging they were denied overtime wages after being improperly classified as overtime-exempt. Password (at least 8 characters required). AmeriHealth Caritas denies that it violated any laws. v. Dr. Courtney N. Phillips There is a class action lawsuit pending against LDH in federal court at the Middle District of Louisiana bearing the caption A.A. et al. But AmeriHealth ordered her daily in-home aide hours cut to two hours, she testified. /Type /Page Disability Rights claimed in a June 2017 lawsuit that levels of care for people with serious disabilities are being terminated, reduced or denied without legal justification, often violating constitutionally protected due process, through engaging in vague, subjective, arbitrary and secret criteria.. /Annots [] /Type /Pages /Filter /FlateDecode Earlier this month,the Register published an investigation showing hundreds of cases where Medicaid recipients have appealed what they say are illegal denials of care. 2:14-cv-00656 in the Pennsylvania Eastern District Court. AmeriHealth Caritas is a subsidiary and/or an affiliate of AmeriHealth, Inc., a Pennsylvania corporation with . Simplified Chinese (PDF) Spanish (PDF) Vietnamese (PDF) The member handbook on this website is the most up-to-date version. 22 0 obj It is against the law for an employer to retaliate against a person for joining a lawsuit to reclaim unpaid wages. We strongly disagree with the judges decision, said DRI Director Jane Hudson. >> Defendants. << 201 : Jury Demanded By: Plaintiff: RSS Track this Docket Docket Report . endobj /Contents [60 0 R 61 0 R 62 0 R] /C2_0 50 0 R /Parent 11 0 R There is no evidence in the record that the issues complained of by the plaintiffs relate to other managed care organizations, the state lawyers wrote. /Resources << However, you do not need to have records of your work hours to make a claim. 27 0 obj Please do not send any confidential information There is no money currently available and there is no guarantee that you will receive money for participating in the lawsuit. This is a pending lawsuit. /TT0 39 0 R << endobj If you have any questions or want to know more about the survey, please call Member Services at 1-888-991-7200 (TTY 1-888-987-5704 . R. Steven Whalen, U.S. Magistrate Judge. AmeriHealth Caritas Services, LLC Et. Filed: August 15, 2017 2:17-cv-03697-GJP. >> /Resources << /Parent 12 0 R |e H?'hQSrWS}NZ?V Doocy also believes the in-home assistance provided to her son has saved taxpayer dollars, citing the overall and ongoing costs of long-term institutionalized care. /quotesingle 96 /grave 128 /bullet /dagger /daggerdbl /ellipsis /emdash /endash 17-3697, see flags on bad law, and search Casetext's comprehensive legal database All State & Fed. /TT3 46 0 R /ProcSet [/PDF /Text] You have to know whats happening with clients, competitors, practice areas, and industries. Must show that such practices are likely to affect them in the past not... Doocys son Marty Matteson has Down syndrome and lives in his own with... 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