Washington National Insurance Company is based in Carmel, Indiana. Ass'n, 936 A.2d 1178, 119091 (Pa.Super.2007)). Your premium rate will not be increased by this conversion.Cancer Policy, at 1; see also id. They indicated to me that they sent me 10 emails, I HAVE RECEIVED NONE. My husband died of cancer on September 28, 2021. I have an accident policy, hospital policy, critical illness and cancer policy with Washington National. Commission based ONLY. Notice of the required premium will be mailed to you at your last known address. Called and was told give it a little more time. Co., 861 A.2d 979, 984 (Pa.Super.2004) (two-year limitation period began running at initial denial of coverage for damage to insured's property under first-party fire policy), aff'd, 932 A.2d 877 (Pa.2007); Adamski, 738 A.2d at 1040 (limitation period under section 8371 began to run upon first occurrence of refusal to pay). I was told I had to call a different department to make that transaction, because of the kind of account I have I cannot, close my account directly through them. . Therefore, her bad faith claim is time-barred. *Some consumers may elect to not publish the details of their complaints, some complaints may not meet BBB's standards for publication, or BBB may display a portion of complaints when a high volume is received for a particular business. The trial court did not address the statute of limitations issue. Therefore, we cannot pay any benefits to you for the claims you submitted. Exhibit D39. Submitting a response indicates a willingness to work with customers to make things right. A motive of self-interest or ill will may be considered in determining the second prong of the test for bad faith, i.e., whether an insurer knowingly or recklessly disregarded its lack of a reasonable basis for denying a claim. Because Rancosky failed to raise any objection to Conseco's litigation strategy or the conduct of Conseco's counsel until after trial, his claim is waived. DeFazio v. Labe, 507 A.2d 410, 414 (Pa.Super.1986) ([because] judgment n.o.v. On May 15, 2003, Conseco made its first payment on LeAnn's claim in the amount of $3,065.00. 35. A check in this amount was enclosed with the letter. Id. At FindLaw.com, we pride ourselves on being the number one source of free legal information and resources on the web. Compare plans, enroll online, or speak to a licensed agent. Conseco's failure to conduct an meaningful investigation of LeAnn's claim when it undertook to do so in December 2006, and its refusal to reconsider its denial of coverage based on the new information provided by LeAnn in her November 30, 2006 letter, constituted new injuries to LeAnn. at 58. Maybe there should be sanctions on their error, my personal information disclosed by this health insurance agency to WHO KNOWS!I WANT THIS CANCELED AND MY MONEY REFUNDED ASAP PLUS INFORMATION ON THE ***** THEY SENT MY PERSONAL INFO TO. The lawsuit claims the insurer failed to notify policyholders of their right to designate . The California Department of Insurance on Aug. 8, 2017, announced that it will look into claims that Wells Fargo and National General Insurance improperly charged customers for auto insurance. In May 2004, LeAnn's cancer recurred, and she began another course of chemotherapy treatment, wherein she was hospitalized overnight every three weeks for a chemotherapy session from June 2004 through April 2005. 8. As noted previously, when Conseco first undertook to investigate LeAnn's claim in December of 2006, it failed to contact USPS to determine the substantial and material duties of LeAnn's position at the time she was diagnosed with ovarian cancer, the last day she worked at USPS, or whether she had, in fact, used annual and sick leave to extend her payroll status to June 14, 2003. LeAnn filled out and signed a WOP claim form on November 18, 2003. The fact-finder must consider all of the evidence available to determine whether the insurer's conduct was objective and intelligent under the circumstances. Berg v. Nationwide Mut. Since when was a SURGERY a sickness? This is usually not the case, and many families pay more, sometimes much more, than the EFC. The American National Property and Casualty Company (ANPAC) is a division of ANICO that provides auto and homeowners insurance and a variety of specialty lines. The Supreme Court granted allocatur in DeFazio but split 33 concerning whether verdict winners lack standing to move for judgment n.o.v. I filed a claim. Reviewed the document and had many questions! See Condio, 899 A.2d at 1142 (holding that the term bad faith encompasses a wide variety of objectionable conduct). 23. That same year, the policy was converted to a Conseco Secure Pay II Family Cancer Policy, under policy No. at 11. Rancosky asserts that the trial court erred by not considering Conseco's litigation strategy to disavow the applicability of the Manual as further evidence of bad faith. Moreover, despite the occupation-related definitions for disability set forth in the Cancer Policy, Conseco provided no explanation in any of its claim forms that the term disability relates solely to the insured's ability to perform his or her occupational duties. disabled due to cancer for more than 90 consecutive days [5] beginning on or after the date of diagnosis.After it has been determined that the Policyowner is disabled, we will waive premium payments for the period of disability, except those during the first 90 days of such period.Id. Company issued 1099 for 2016 for $3, 371.90 even though they paid me no money for that year. 30. However, suit limitations clauses do not apply to bad faith claims because such claims do not arise under the insurance contract. Additionally, the WOP claim form indicates that Conseco Health reserves the right to request additional information on any claim. Waiver of Premium Claim Form, No. Regards,***************************, ****** ** 46082-1916January 13, 2023 BBB ***********************2601 ***************************************************************************************** RE: Washington National Insurance Company Complainant: *************************** Case ID: ********Dear BBB of ***************:This letter is ** response to the correspondence received ** our office on January 12, 2023.Thank you for allowing us the opportunity to address this matter.In your correspondence you requested additional information regarding a previous BBB complaint submitted by a policyholder with our company. Since then our modes of transportation have . No information on payment or payments was discussed - again, my policy is not effective until 12/1/2022. Co., 167 A. (holding that a new limitations period begins to run from later acts of bad faith). ]Brief for Appellant at 5. In other words, Kelso, in conducting Conseco's first investigation of LeAnn's claim, albeit in response to LeAnn's request for reconsideration, simply reviewed the limited and conflicting information in Conseco's records. My husband passed on Oct 29, 2022. The surgery was for a torn meniscus and carpal tunnel. "We have provided the customer with information regarding two of the policies. I'd like to have the money back that this ** pay took for providing no service/ no insurance for my child and be reimbursed the $161 I haf to pay out of pocket because I was told she would have full **verage for preventive care. Co. of Am., 25 A.2d 697, 69970 (Pa.1942) (holding that, following the insurer's cancellation of the policy, the insured was not required to inform the insurer of a lawsuit filed against him, pursuant to the notice provisions of the policy, noting that the insured was not required to do a vain thing.). Requested agent statement******************************************. at 172. [W]e are not bound by the rationale of the trial court and may affirm on any basis. Richmond v. McHale, 35 A.3d 779, 786 n. 2 (Pa.Super.2012). Filed: March 2, 2023 as 1:2023cv03027. See Bariski v. Reassure America Life Ins. 295, 296 (Pa.1933) (holding that [a]n insurer will not be permitted to take advantage of the failure of the insured to perform a condition precedent contained in the policy, where the insurer itself is the cause of the failure to perform the condition.); see also Slater v. Gen. Cas. FAQ Rancosky asserts that, because LeAnn and Martin were focused on LeAnn's battle with ovarian cancer, they did not immediately notify Conseco of Martin's pancreatic cancer, which was diagnosed on October 28, 2004. Rather, the insurer must actively undertake a meaningful investigation to obtain accurate information bearing upon the coverage inquiry. Exhibit D17. See Pa.R.C.P. Washington National Insurance Company Complaints Complaints Washington National Insurance Company Insurance Companies View Business profile Customer Complaints Summary Business's. If you or your attorney files a civil lawsuit, by law one of you must notify us. 23 complaints closed in the last 12 months. Please see attached letter dated 1.9.23, I have not received any offer from Washington National to resolve this. (Bad Faith Trial), 6/27/14, at 7879). Terletsky, 649 A.2d at 688. 17. Conseco provided no reasonable or rational explanation for its delay in investigating LeAnn's claim. LeAnn also requested insurance identification cards from Conseco. On February 7, 2003, exploratory surgery was performed, after which LeAnn was diagnosed with ovarian cancer. One of the best Insurance business at 11825 N Pennsylvania St, Carmel IN, 46032 United States. Co., 1999 U.S. Dist. We also vacate in part the trial court's Judgment entered on August 1, 2014, solely as it relates to LeAnn's claim for bad faith, and remand for a new trial on LeAnn's claim for bad faith .36. I was told to fill it out, sign it, and she would forward over so I can receive my funds. Because the cornerstone of Rancosky's first issue is that the trial court committed error in the application of law by requiring Rancosky to prove a dishonest purpose or motive of self-interest or ill-will in order to establish bad faith on the part of Conseco, this issue raises a question of law. 10. I have requested call backs and one time they called back only to tell me that my letter is being reviewed. LEXIS 95686 at *15, *22 (W.D.Pa.2014) (denying the insurer's motion for partial summary judgment on the insured's claim for bad faith, and holding that the insurance company must conduct a meaningful investigation, which may include an in-person interview, examination under oath, medical authorizations, and/or independent medical examinations, and noting that the insurer did not attempt any of the foregoing.); Bonenberger, 791 A.2d at 381 (noting that the trial court determined that the insurer acted in bad faith when it, inter alia, disregarded the insured's medical records, conducted no independent medical examination, and made no reasonable evaluation based on the insured's presentment). The credit score ban would likely affect most policyholders' rates in some way. Here, Rancosky did not raise this issue at any time before or during the bad faith trial. 7. Because the sole basis for the trial court's verdict on LeAnn's bad faith claim against Conseco was that Rancosky failed to establish the first prong of the test for bad faith (i.e., that Conseco lacked a reasonable basis for denying benefits to LeAnn under the Cancer Policy), we need not determine whether the evidence of record supports a finding regarding the second prong (i.e., that Conseco knew of or recklessly disregarded its lack of a reasonable basis in denying benefits to LeAnn). The Knights of Columbus is also currently embroiled in a major contract dispute lawsuit involving alleged insurance fraud The Knights of Columbus (KofC) gave a lucrative lobbying contract to a firm that employed Supreme Knight Carl Anderson's son in 2017, leading the younger Anderson to become the chief lobbyist for the organization . Nationstar Mortgage, which rebranded as "Mr. Cooper," agreed to a $91 million settlement this week for allegedly violating consumer protection laws after the Great Recession. A few days later I followed up with Washington national to see if they received *** email, I was told they did receive it but it was denied because it was the wrong from, and I have to fax in the correct form to them, after stating earlier I can't withdraw my funds through them. The completed statement, signed by one of LeAnn's physicians on August 27, 2006, incorrectly indicated that LeAnn's cancer was first diagnosed on December 7, 2003. Ins. Id. Thus, the trial court entered judgment in favor of Conseco based on its determination that Rancosky failed to satisfy the first prong of the test for bad faith. Thus, the statute of limitations begins running when the insurer sends a letter denying a claim, even where the insurer later agrees to re-evaluate a decision to deny benefits at the request of the insured. This work is licensed under a Creative Commons Attribution-NoDerivs 3.0 Unported License 2023 Online Legal Media. Despite Conseco's decision to terminate the Cancer Policy, a Conseco internal memo, issued in January 2004, acknowledged problems in the billing process for payroll deduction policies, and indicated that Conseco is working with policyholders in an effort to allow their policy to remain current as valid claims are considered. Trial Court Opinion, 11/26/14, at 18. Please contact us Monday through Friday at (800) 523-9100 between 8:30 a.m. and 5:30 p.m. EST. However, she had unused vacation and sick days, which extended her employment status to June 14, 2003,9 despite the fact that she did not work after February 4, 2003. 33. Co. (majority) Annotate this Case Justia Opinion Summary In this discretionary appeal, and in a matter of first impression, the Pennsylvania Supreme Court considered the elements of a bad faith insurance claim brought pursuant to Pennsylvania's bad faith statute, 42 Pa.C.S. If your auto and home are damaged in the same. Washington National sent me a 'Premium Audit' which clearly shows that all premiums are paid a month in advance, they are now trying to tell me that is not the case. I concur with the majority's decision to affirm the entry of summary judgment in favor of Conseco1 on Martin's claims. The claim forms initially submitted by LeAnn did not include any section that was required to be completed by a physician. Co., 734 A.2d 901, 906 (Pa.Super.1999) (same). Indeed, when Conseco finally undertook to investigate LeAnn's claim in December 2006, Conseco did not contact LeAnn's employer, USPS, to determine the substantial and material duties of LeAnn's position at the time she was diagnosed with ovarian cancer, the last day she worked at USPS, or whether she had, in fact, used annual and sick leave to extend her payroll status to June 14, 2003. In analyzing the order of [a] trial court that granted summary judgment [ ], our scope of review is plenary. See Trial Court Opinion, 11/26/14, at 8. Through [USPS,] I had sick and annual leave which I used until my disability [retirement] was approved. at 1040. Auto. However, the rule didn't go into effect and is in legal limbo due to a lawsuit, according to The Seattle Times. No. Fire Ins. Id. On January 5, 2007, Kelso sent another letter to LeAnn, wherein he confirmed Conseco's position that the Cancer Policy had lapsed on May 24, 2003. Co., 908 A.2d 888, 89596 (Pa.2006) (internal citations omitted). On March 21, 2012, the trial court granted summary judgment in favor of Conseco on all of Martin's claims. Brief for Appellant at 57. I attached all papers I originally filed for my claim with when I had surgery on April 20 2022.According to my paperwork diagnosis says one thing BUT procedure says another. Please complete this form to request a review of your complaint by an attorney. I verified that it was sent by her. Jurisdiction relinquished. Here, the trial court dismissed Martin's claims against Conseco on the basis that he never provided [Conseco] with written notice of a claim or written proof of loss as required by the language of the [Cancer P]olicy. Trial Court Order, 3/21/12, at 1. 27. No call back or paperwork sent like I was told would happen. Through our partnership with Cognicion, we have developed a site dedicated to tracking this litigation available through the linked map below. My husband was a veteran. The news sent shares . Notably, Conseco was informed by LeAnn, at the outset of her claim, that she had been disabled, as that term is defined in the Cancer Policy, for more than 90 consecutive days from her first hospitalization on February 4, 2003. See Condio, 899 A.2d at 1145 (holding that, if evidence arises that discredits the insurer's reasonable basis, the insurer's duty of good faith and fair dealing requires it to reconsider its position); see also Hollock, 842 A.2d at 413 (noting the trial court's determination that the insurer acted in bad faith based on, inter alia, its failure to re-evaluate the value of the insured's claim, despite having received several pieces of information which should have caused it to re-evaluate the claim value). Liberty Ins. Washington National is dedicated to serving the needs of Americans who've worked hard and want to protect the health and well-being of themselves and their loved ones. Conseco did not advise LeAnn that there was any problem with her request for WOP or her claim submission. I signed the authorization to release medical information so that they can request whatever records they need for my claim but they keep telling me I have to request them and send them in. R.I. Gen. Laws 23-13-17 (1987) establishes the WIC program to provide supplemental foods and nutrition education to breastfeeding women. Because we conclude that Conseco lacked a reasonable basis to deny benefits to LeAnn under the Cancer Policy, raised as issue 1, we need not address Rancosky's sub-issues at 1.A. Co., 44 A.3d 1164, 1179 (Pa.Super.2012) (citations omitted). LeAnn was Conseco's insured and, therefore, a heightened duty of good faith was imposed on Conseco in this first-party claim because of the special relationship between the insurer and its insured, and the very nature of the insurance contract. ET. One week later, in correspondence dated September 21, 2006, Conseco denied LeAnn's claim for further benefits, stating [y]our CANCER insurance coverage ended on 52403. The Cancer Policy contains a Waiver of Premium (WOP) provision, which provides as follows:Subject to the conditions of this policy, premium payments will not be required after the Policyowner is: diagnosed as having cancer 30 days or more after the Effective Date; and. Please note that this is an estimate and may be impacted by the unique circumstances of your request. The record reflects that Conseco did not purport to conduct any investigation regarding LeAnn's claim until it received LeAnn's request for reconsideration in December of 2006, eighteen months after it had first received conflicting information regarding the starting date of LeAnn's disability. In order for us to conduct additional research,we need more information, such as the insureds social security numbers and last address of record, copies of the policies, paid-up certificates or any available recent correspondence from our company includingproof of recent premiums, if applicable.Please advise **************** to send this additional information to the address listed in our recent correspondence to her, and we will be happy to further research this matter. In correspondence dated April 12, 2006, Conseco denied LeAnn's claim for further benefits, stating [y]our CANCER insurance coverage ended on 52403. Although the Cancer Policy contained a suit limitations clause, such clauses operate to limit the insured's claims arising under the policy, such as a breach of contract claim. The filing instructions on the claim form indicate that CONSECO RESERVES THE RIGHT TO REQUEST ADDITIONAL INFORMATION ON ANY CLAIM FOR DETERMINATION OF BENEFITS. Conseco Claim Form, No. See Mohney, 116 A.3d at 1135 (holding that the insurer's investigation was not sufficiently thorough to obtain the necessary information regarding the insured's ability to work, noting that the insurer made no attempt to contact the insured's physician to obtain clarifying information, and terminated the insured's benefits without obtaining an independent medical examination); see also Mineo v. Geico, 2014 U.S. Dist. See, e.g., Jones v. Harleysville Mut. at 8 (footnote added).Pursuant to the Cancer Policy, disabledMeans that: for the first 24 months after loss begins you are unable, due to cancer, to perform all the substantial and material duties of your regular occupation; andAfter 24 months, disabled means that: you are unable, due to cancer, to work at any job for which you are qualified by reason of education, training or experience; you are not working at any job for pay or benefits; and. In the context of an insurance claim, a continuing or repeated denial of coverage is merely a continuation of the injury caused by the initial denial, and does not constitute a new injury that triggers the beginning of a new limitations period. Bad faith conduct also includes evasion of the spirit of the bargain, lack of diligence and slacking off, willful rendering of imperfect performance, abuse of a power to specify terms, and interference with or failure to cooperate in the other party's performance. See Hollock, 842 A.2d at 414. Most policy service requests take an average of 13 to 15 business days to process upon receipt. Totals on 1099's for the three years exceed money paid to me for that same period. from Pioneer Life Insurance Company in the state of Florida where Pioneer Life
Exchange, 899 A.2d 1136, 1143 (Pa.Super.2006). Washington National Insurance Company is not licensed and does not solicit business in the state of New York. Even if this issue had not been waived, we could not grant relief to Rancosky. Note that complaint text that is displayed might not represent all complaints filed with BBB. $5.6B Co., 738 A.2d 1033, 104243 (Pa.Super.1999). OLYMPIA, Wash. Nov. 9, 2021 1:57 p.m. it feels like this company is trying to keep my money by giving me the run around, no one called me or emailed me the second time to tell me my form was denied again, if I hadn't of called for an update. LeAnn died on February 18, 2010, and her Estate was substituted as a plaintiff. or Washington National has rejected all or a portion of a claim on the Policy
Once we know, we may file a notice with the court about our interest in recovery. Please see attached. The case could serve. See Trial Court Opinion, 11/26/14, at 19 (concluding that Conseco waited entirely too long to begin such an investigation[,] given the number and frequency of [LeAnn's] communications with the company regarding her WOP provision). However, there is an important distinction between an initial act of alleged bad faith conduct and later independent and separate acts of such conduct. He died after being treated for conditions including prostate cancer. Sales Agent (Former Employee) - San Antonio, TX - November 5, 2020. The complaint charges the Washington National Insurance Corporation with claims for breach of contract. LeAnn did not respond to that correspondence. Had Conseco conducted a meaningful investigation into the starting date of LeAnn's disability, it would have determined that she had been disabled due to cancer for more than 90 consecutive days, beginning on February 4, 2003, and that she was entitled to the WOP benefit provided by the Cancer Policy. CA458 (07/02), at 1 (unnumbered). [Whether t]he trial court's July 3, 2014 Verdict and Finding that Conseco had not acted in violation of 42 Pa.C.S.A. Annuity payout options. He told me to call him anytime and provided me with his personal # but that was incorrect.11/16/2022 - Called and talked with ****?! [Whether t]he trial court erred by finding it was reasonable for Conseco to place its interests above those of [LeAnn and Martin? 0. I have made multiple attempts to connect with them in hopes of resolving this issue and I cannot get anyone to even give me a call back. In the bad faith trial, David Rikkers (Rikkers), Conseco's Legal Interface Compliance Analyst, testified that the Manual is not used for adjudicating these types of claims. Trial Court Opinion, 11/26/14, at 1617 (citing N.T. On March 9, 2005, Conseco sent a letter to LeAnn indicating that it had recently conducted an audit of its cancer policies and [o]ur records indicate that you previously owned this type of policy, but ceased paying premium on or about JUNE 24, 2003. LeAnn paid a monthly premium rate of $44.00 for the Cancer Policy. Called the office and **** was not available. Therefore, at the latest, the two-year bad faith statute of limitations began running on September 21, 2006. Id. We were unable to locate the remaining two policies in question. They would get the benefit of rising interest rates, but if interest rates fell below 6 percent, they would still get 6 percent. Rancosky notes that that Conseco's Manual was admitted into evidence, without objection, at the breach of contract trial. Condio v. Erie Ins. Rancosky contends that, despite the trial court's finding that Martin failed to provide Conseco with the correct form of notice in order for Conseco to evaluate his claim, all of the information required in a proof of loss form was provided to Conseco through litigation. See details. As the verdict winner, Conseco could not file post-verdict motions objecting to the trial court's failure to decide the statute of limitations issue. Dear Senate Members and Attendees: My name is Robert Wallace Malone. Additionally, the WOP claim form included an authorization, signed by LeAnn, which was the same as the authorization signed by LeAnn on July 25, 2003. Residents of Florida Against Washington National or Pioneer Life Legal Help See Shelhamer, 58 A.3d at 770.35. Brief for Appellant at 30 (citing Greene v. United Servs. In his final issue, Rancosky contends that the trial court erred by entering summary judgment in favor of Conseco on Martin's claims. As of year-end 2016, CNO had roughly $4 billion in revenue and $263 million in operating income. Please feel free to reach out to me at any time regarding this matter as your assistance is greatly appreciated. [ ] 1171.5(a)[? POLICY WAS CANCELLED BY ****, THEN HE CHANGED IT. Bad faith claims are fact specific and depend on the conduct of the insurer vis vis the insured. Nor can the plaintiff extend the limitations period by arguing that the insurer's bad faith conduct was continuing, because the plaintiff is not entitled to separate initial and continuing refusals to provide coverage into distinct acts of bad faith. Adamski, 738 A.2d at 1042; see also CRS Auto Parts, Inc. v. Nat'l Grange Mut. What to do when changing annuity policies. See Trial Court Opinion, 11/26/14, at 19. A Conseco representative advised LeAnn that the Cancer Policy had lapsed as of May 24, 2003. Plaintiff: Union Gospel Mission of Yakima Wash. 8371. Using the April 21, 2003 date provided in the first completed WOP claim form as LeAnn's starting disability date, the 90day waiting period required to trigger the waiver of LeAnn's premiums would not expire until July 21, 2003, a date beyond the period for which premiums for the Cancer Policy had been paid. I called and the lady I spoke to said it was denied. Therefore, we cannot pay any benefits to you for the claims you submitted. Conseco Letter, 9/21/06, at 1. His suit alleged that. Instead, the trial court entered a Verdict in favor of Conseco on LeAnn's bad faith claim. I said NO *****S received. LeAnn and Martin instituted this lawsuit on December 22, 2008, by filing a Praecipe to issue a writ of summons. (citing Trial Court Opinion, 11/26/14, at 19). However, because the premium payments were made in arrears, the final premium payment extended coverage under the Cancer Policy only to May 24, 2003.10. RANCOSKY DBN v. WASHINGTON NATIONAL INSURANCE COMPANY. With this in place, beneficiaries. 0 Comments. See Arlotte v. Nat. On this day, I spoke with *********************************, agent who informed me I will be receiving emails on my policy and other information. Co., 649 A.2d 680, 688 (Pa.Super.1994)). Conseco assigned Compliance Department analyst Dustin Kelso (Kelso) to respond to LeAnn's November 30, 2006 letter. Customer Reviews are not used in the calculation of BBB Rating, I had a life insurance policy with Washington national insurance, I requested to close my account and withdraw the funds I have available. Accordingly, Conseco deemed the Cancer Policy to have lapsed on May 24, 2003, due to non-payment of premiums prior to the expiration of the 90day waiting period on July 21, 2003. Thus, viewing the record in the light most favorable to Rancosky, as the nonmoving party, we cannot conclude that the trial court committed an error of law or abused its discretion in granting summary judgment in favor of Conseco and dismissing Martin's claims. Facing a lawsuit and political opposition, Washington State Governor Jay Inslee has delayed until April a payroll tax aimed at funding the state's first-in-the-nation public long-term care . In a letter dated September 21, 2006, Conseco denied this request for WOP benefits and again advised LeAnn that Your CANCER insurance coverage ended on 52403. The WOP claim form included a Physician Statement section to be completed by Physician's Office and signed by one of LeAnn's physicians. Doing so places you under no obligations and does not establish an attorney-client relationship.
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