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Real estate agents’ broad duty of care discussed by Maryland federal court
In Lawley v. Northam, a case recently decided by the U.S. District Court for the District of Maryland, the court explored the scope of a real estate agent's liability for making material misstatements or omissions concerning a property for sale. Lawley v. Northam, 2011 U.S. Dist. LEXIS 37690 (D. Md. Apr. 5, 2011). In that case, the defendant was a real estate agent who represented the seller of a single family home in Worcester, Maryland. The plaintiffs, Mr. and Mrs. Lawley, were the daughter and son-in-law of the buyer, and were renting the house.
The Lawleys filed a complaint alleging that the real estate agent had failed to disclose material defects in the property relating to mold, asbestos, and water intrusion. The agent moved for summary judgment, asserting that she had no obligations to the buyer or to the Lawleys because she was not their agent -- she represented the seller. Therefore, she claimed she could not be held liable for economic loss suffered by the plaintiffs.
The court denied the motion, pointing to Maryland statutes and regulations which require real estate agents to disclose all material facts to any person with whom they conduct business. For example, one Maryland regulation imposes an affirmative obligation on real estate agents to avoid "error, exaggeration, misrepresentation, or concealment of material facts." COMAR 09.11.01.D. On the basis of these statutes and regulations, the court held that a seller's real estate agent does, in fact, owe a duty of care to the buyer and can be held liable for failing to disclose material facts. The court acknowledged that in this case the Lawleys were not the buyers of the property, but only rented the property from the buyer. However, the court found that the Lawleys were sufficiently involved in the real estate transaction to maintain a suit against the seller's agent.
On the other hand, the court was careful to point out that a real estate agent will only be liable for failing to disclose material information that she knew or should have known. If a real estate agent is unaware, through no fault of her own, of a material defect in property that she is trying to sell, she cannot be held liable for non-disclosure.
For advice on potential matters involving the liability of real estate agents in Maryland, contact Deborah M. Whelihan, Esq. at 202-296-4747.
Posted by Raphael Cohen on 06/02/2011 at 02:04 AM
Liability of Agents and Brokers •
Maryland •
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Fire cause and origin expert excluded by Maryland federal judge under Daubert analysis
In Fireman's Fund Insurance Company a/s/o Mangione Family Entpr. v. Tecumseh Products Co., et al., Civil Case No. JKB-09-2811 (D. Md. Mar. 2, 2011), the United States District Court for the District of Maryland excluded plaintiff's causation expert for failing to meet the generally accepted standards for fire investigation and failing to satisfy the requirements set out in Daubert v. Merrell Dow Pharmaceuticals, 509 U.S. 579 (1993) and its progeny, which resulted in the Court granting summary judgment for defendants.
On November 13, 2006, the Hilton Garden Inn in Owings Mills, Maryland suffered a fire and resulting damage of approximately $100,000 which plaintiff, Fireman's Fund Insurance Company paid pursuant to an insurance policy issued to Mangione Family Enterprises, the hotel owner.
As Mangione's subrogee, Fireman's Fund retained two certified fire investigators to determine the cause of the fire. After an investigation, the first expert concluded that the fire originated in the heat pump room and was caused by an undetermined failure or malfunction of the heat pump. Plaintiff's second expert, Kenneth McLauchlan, was retained to determine the exact cause of the hypothesized failure of the heat pump.
The chief building engineer reported that other heat pumps had malfunctioned and that the compressors had to be replaced regularly. McLauchlan concluded that the heat pump was the only plausible source of the fire and took possession of three heat pumps from the hotel, including, the "subject" heat pump that caused the fire, and two exemplar pumps (a working heat pump and a similarly damaged heat pump). McLauchlan examined and compared the three pumps and concluded that a manufacturing defect caused the compressor failure which caused the fire.
Defendants moved to exclude McLauchlan's testimony and the Court agreed. The Court concluded that under Daubert and its progeny, the methodology McLauchlan employed to reach his conclusions was unreliable. In particular, the Court held that NFPA 921, the generally accepted standards for fire investigation, instructs the investigator to collect data about the fire "by observation, experiment, or other direct . . . means, to analyze the data objectively and without speculation, to develop a hypothesis based solely on the data collected, to test the hypothesis by comparing it to all known facts, and to repeat the process until all feasible hypotheses have been tested. Until these steps are completed, NFPA 921 unambiguously requires an investigator to list the cause of the fire as undetermined."
The Court focused on the testing requirements under Daubert, noting that the failure to properly test a hypothesis is often grounds for excluding expert testimony. Also, the expert must rule out alternative hypotheses. Further, experts are required "to demonstrate that objects and materials are capable of behaving in the manner they hypothesize under the conditions of the event in question."
Even though McLauchlan's report had a section titled "Methodology", it failed to describe the tests utilized in forming his hypothesis. The Court found that McLauchlan had formed his hypotheses through speculation, merely relying on similar damage between the exemplar and subject heat pumps, having never tested his hypothesis, instead deriving his final hypothesis from his observations of the exemplar heat pumps, rather than testing it against them. The Court determined that McLauchlan's sample size of one being insufficient to rule out an otherwise plausible hypothesis. Also, McLauchlan failed to test and exclude a plausible alternative explanation for the fire. Consequently, in excluding McLauchlan's testimony, the Court held that McLauchlan did not meet the generally accepted standards of fire investigation set out in NFPA 921 and did not satisfy the requirements of testing and ruling out other hypotheses as required by Daubert and its progeny. Since Plaintiff's other expert relied upon McLauchlan's findings in formulating his opinions, the Plaintiff's were left without an expert to testify as to causation and the Court granted defendants' motion for summary judgment.
Posted by Robert Anderson on 05/29/2011 at 03:09 PM
Expert Witness Issues •
Maryland •
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Jordan Coyne & Savits, L.L.P.‘s most recent newsletter, “Extraordinary Writs”, is now available
The most recent issue of Jordan Coyne & Savits, L.L.P.'s newsletter is available here.
Posted by David B. Stratton on 04/12/2011 at 03:20 PM
District of Columbia •
Maryland •
Virginia •
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Foreign subpoenas are still often a foreign concept
Trial lawyers in the Washington, D.C. metropolitan area soon realize that almost every case can require discovery across jurisdictional boundaries. For cases where there is diversity or federal question jurisdiction, removal to federal court makes discovery easier. But when removal is not an option, the Uniform Interstate Deposition and Discovery Act (UIDDA) steps in to relieve (some of) the burden.
UIDDA is a short act that streamlines the process for obtaining subpoenas in foreign jurisdictions by eliminating the need to open a miscellaneous matter with the court. Also, a request for a foreign subpoena under UIDDA no longer constitutes an appearance in court. Accordingly, UIDDA has the added benefit of saving clients the cost of opening a matter and retaining local counsel.
Under UIDDA, one can, in theory, simply present the Clerk of the Court for the area where discovery is sought to be conducted (the discovery state) with a completed subpoena issued from the state where the action is pending (the foreign subpoena). The Clerk then issues a subpoena from the discovery state using the information on the foreign subpoena and the subpoena can be served by any means of permissible service in the discovery state.
UIDDA has now been adopted by the District of Columbia, Virginia, Maryland and Delaware, but it is not as uniform as its name might suggest.
Under the Virginia Uniform Interstate Deposition and Discovery Act, Va. Code secs.8.01-412.8 through 8.01-412.5, the 'privilege' of the simplified process only applies "if the jurisdiction where the action is pending has enacted a similar privilege to persons in [Virginia]." This means that the UIDDA procedure is only available if the litigation is pending in a jurisdiction that follows UIDDA or one of its predecessors such as the Uniform Foreign Depositions Act. For enforce this provision, Va. Code sec. 8.01-412.10 requires a completed subpoena from the litigation state as well as "a written statement that the law of the foreign jurisdiction grants reciprocal privileges to citizens of the Commonwealth for taking discovery in the jurisdiction that issued the foreign subpoena." In addition, Virginia clerks request a Virginia State Foreign Subpoena form completed without signature.
We have recently had an opportunity to request foreign subpoenas in the Circuit Courts for Spotsylvania and Fredericksburg, Virginia. All of the requested subpoenas were issued with nominal fees and served by the respective Sheriff without difficulty.
The Clerk's Office of the Circuit Court for Fairfax County, Virginia, has published a guide to the implementation of UIDDA in that court, and the same procedures will probably work in most Virginia Circuit Courts. All courts in jurisdictions that have adopted UIDDA should promulgate similar guides, in the interests of judicial economy and the sound administration of justice.
The District of Columbia has adapted UIDDA at D.C. Code sec. 13-441 through 13-448. Though the language of The D.C. UIDDA mirrors the model language, the court stated in Charca-Lupaca v. Maza, D.C. Super. Ct. No. 2010 CA 6934 2 (Daily Washington Law Reporter, Vo. 138, No. 252, Page 2669), that the subpoena from the litigation state must be accompanied with a completed subpoena for the District of Columbia. The Court further cautioned that an exception to the streamlined process of issuance of subpoenas under UIDDA exists for medical records. Subpoenas requesting the production of medical records that fall under D.C. Code 14-307 will not be issued until the party requesting the documents appears before the court and makes the required showing that the records should be produced.
Maryland and Delaware have adopted UIDDA with few changes or modifications. See Md. Courts & Judicial Procedure, secs. 9-401 - 9-407, and Del title 10, section 1, ch 43, sec. 4311. Despite Maryland's early adoption of UIDDA, Maryland clerks have been slow to embrace the Act.
We have had mixed success requesting subpoenas under UIDDA in Maryland. Our request to the Circuit Court for Baltimore City was rejected because the case number was missing and they required "something certified." This rejection due to a missing case number seems to indicate that Baltimore City continues to require a miscellaneous matter. The Circuit Court for Montgomery County has accepted the request for a foreign subpoena, but has requested an $80.00 filing fee which is the same fee as opening a miscellaneous matter.
In short, the UIDDA is a vast improvement over the days of appointing commissioners to issue subpoenas in foreign jurisdictions, but functionally, some of the wrinkles remain. Because not all Courts appear to be following UIDDA, the best practice is always to call the Clerk of the discovery jurisdiction and follow the procedures they prescribe. Those procedures may be far more complicated than required by UIDDA, but they are more likely to result in a timely foreign subpoena.
Posted by Sara A. Corle on 03/18/2011 at 09:52 PM
District of Columbia •
Maryland •
Virginia •
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Surety must arbitrate disputes based on contract incorporated by reference in bonds
In Developers Surety and Indemnity Co. v. Resurrection Baptist Church, Case No. RWT 10cv1224 (D. Md. Dec. 1, 2010), the Court held that the surety must arbitrate disputes related to performance bonds where the performance bonds specifically incorporated by reference construction contracts containing an arbitration clause. In so holding, the district court followed precedent in the First, Second, Fifth, Sixth and Eleventh Circuits.
In addition, the Court found that the surety is equitably estopped from refusing to arbitrate its disputes with the co-obligees under the performance bonds. The Fourth Circuit has held in a non-surety context that a nonsignatory is estopped from refusing to comply with an arbitration clause when it receives a direct benefit from a contract containing an arbitration clause. Here, the surety asserted claims against the co-obligors for breach of the building contract, but simultaneously sought to avoid enforcement of the arbitration clause in the same contract.
The Court also rejected the surety's argument that arbitration was waived because the opposing parties had filed their answers, asserted crossclaim and counter-claims, and engaged in some discovery. The Court, following Fourth Circuit precedent, observed that absent a showing of prejudice, a court will not find waiver where the parties seeking to arbitrate merely answered pleadings and engaged in minimal discovery. Thus, the Court held that defendants did not waive their right to insist upon arbitration of this dispute.
Posted by David B. Stratton on 01/19/2011 at 06:59 PM
Arbitration •
Maryland •
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Fourth Circuit affirms award of summary judgment to defense in employment discrimination case
In Mascone v. American Physical Society, Inc., the Fourth Circuit affirmed the District Court's award of summary judgment to the defendant, and the District Court's denial of the plaintiff's motion for reconsideration.
The Court affirmed summary judgment on the wrongful termination claim, finding that the plaintiff failed to demonstrate that the employer used a forbidden consideration with respect to any employment practice. Further, she failed to show that the employer's proferred reasons for her dismissal were pretextual.
Further, the Court affirmed summary judgment on the plaintiff's pre-termination, gender-based disparate treatment claim. The plaintiff could not establish a prima facie case because she could not show that the other employee in question was similarly situated.
The Court rejected the plaintiff's mixed-motive claim under Title VII, because the plaintiff did not show that the protected trait actually motivated the employer's decision.
Finally, the Court affirmed the award of summary judgment on the plaintiff's retaliation claim. The plaintiff hired a firm to contact the employer pretending to be a potential employer. Plaintiff contended that she was given negative references in retaliation for engaging in protected activity. The Court found that plaintiff could not prove dissemination of false reference information that a prospective employer would view as material to its hiring decision.
Deborah Murrell Whelihan, Esq., of Jordan Coyne & Savits, LLP, represented the defendant in this matter.
Posted by David B. Stratton on 01/13/2011 at 04:15 PM
Employment Discrimination •
Maryland •
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Countering A Plaintiff’s Counsel’s Minimal Expert Witness Disclosures in Lead Paint Litigation
In the Jamal Logan v. LSP Marketing Corp., et al., the Court of Special Appeals upheld the trial court's granting of an order in a lead paint case precluding all but one of plaintiff's 12 experts as a sanction for failure to comply with Md. Rule 2-402(g) (i.e. failing "to state the subject matter, substance of the findings/opinions, and summary of grounds for each opinion; and produce any reports, to which the expert is expected to testify.")
Defendant's interrogatories requested information as to Plaintiff's experts. When Plaintiff did not respond to the interrogatories within the time prescribed, defense counsel made a good faith effort to resolve the dispute. Plaintiff's counsel eventually submitted its answers to interrogatories, but failed to provide any substantive information. Not having received sufficient or satisfactory information, Defendant moved to dismiss/compel. The Court compelled Plaintiffs to supplement their responses, but Plaintiff's counsel again responded vaguely and did not produce any reports. Consequently, Defendant moved for sanctions to exclude the experts or dismiss. The Court precluded all but one expert. As a result, Plaintiff was unable to put on a prima facie case resulting in the Court granting Defendants motion for summary judgment.
This opinion reiterates the expert designation requirement, specifically,
Plaintiff's answers to interrogatories did not comply with Rule 2-402 because he failed to include the substance of the experts' findings and opinions, as well as a summary of the grounds for each expert's opinion. For example, Plaintiff listed Mark Lieberman as a vocational rehabilitation expert who would testify "as to the vocational impact and loss of potential earning capacity of lead paint poisoning on the Plaintiff(s)." Although Plaintiff stated that Lieberman would "base his opinions on a review of the medical records, school records, other expert reports and depositions," Plaintiff did not state how Lieberman believed his earning capacity would be affected. In addition, Plaintiff listed 12 individuals, 10 of whom were located out-of-state, as experts in pediatric lead poisoning, who would "testify to the extent and permanency of the minor Plaintiff?s injuries due to exposure to lead paint." These answers failed to disclose, however, what each expert would opine as to the extent and permanency of the injuries, which might range from 0% to 100%. Plaintiff stated that all 12 experts were expected to "testify to the probable source of the lead exposure," but he did not include what each expert would opine the probable source was, and why the expert expressed this belief. Moreover, the experts were to "testify that exposure to lead-based paint at all of the defendants' subject premises . . . was a substantial factor in the plaintiff's injuries," yet Plaintiff did not state the reasons for their findings. And, Plaintiff stated at the end of each expert designation that a written report "will be provided when available" or "as soon as it becomes available." But none were provided. "Based upon Plaintiff's "boilerplate" expert designations, it was reasonable for the court to infer that the excluded experts' testimonies would be duplicative of Dr. Hurwitz's" (the only properly designated expert).
Also, noteworthy, the Plaintiff argued as a defense that Defendants could have taken the experts' depositions. However, since 10 experts were out of state the Court emphasized the importance of Plaintiff's compliance with Md. Rule 2-402(g) to provide a proper designation so that the Defendant did not have to unnecessarily incur the costs associated with depositions.
Posted by Robert D. Anderson on 01/04/2011 at 03:06 PM
Expert Witness Issues •
Lead Paint Poisoning •
Maryland •
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Motion to Dismiss Upheld for Failure to State a Claim and Failure to Obtain Leave to Amend
In Rashid Mohiuddin v. Doctors Billing & Management Solutions, Inc., et al., ________ Md. App. _________ (Nov. 1, 2010), the Court of Special Appeals addressed two issues; (1) whether the trial court had sufficient grounds to dismiss Plaintiff?s complaint on the grounds that it failed to state a cause of action, and (2) whether the trial court was correct in dismissing Plaintiff's fourth amended complaint for failure to amend his complaint in accordance with Maryland Rule 2-322(c).
Mohiuddin was a physician who entered into an employment contract whereby he agreed to provide physician services to Doctors Billings' patients in exchange for salary and benefits. In addition, Mohiuddin would occasionally be assigned to see patients of Physicians House Calls, Inc. (PHC), a separate corporation that provides patients with physicians for home visits.
Mohiuddin filed a second amended complaint to recover unpaid wages and restitution for work he performed under his employment contract and asserted three counts against PHC: (1) violation of Maryland's Wage Payment and Collection Law; (2) quantum meruit; and (3) unjust enrichment. PHC responded by filing a motion to dismiss for failure to state a claim. The trial court granted PHC?s motion because it "didn?t believe that there's been a sufficient demonstration of a connection to [PHC] to justify leaving them in at this time."
The three claims were addressed as follows:
(1) Violation of Maryland's Wage Payment and Collection Law - Mohiuddin failed to allege sufficient facts to raise an inference that he was either engage to work by PHC, or that PHC exercised any degree of control over appellant in his work as a physician.
(2) Quantum Meruit - Mohiuddin failed to allege that either Doctors Billing or PHC was obligated to pay him for his services with PHC. Without the allegation that both parties intended that PHC was required to pay him for his services, Mohiuddin failed to plead the existence of a mutual agreement between the parties.
(3) Unjust Enrichment - Mohiuddin was required to plead facts comprising the cause of action with sufficient specificity, however, the Complaint failed to assert that PHC was enriched and left the Court guessing why equity would require PHC to compensate him.
In upholding the dismissal for failure to state a claim, the Court stated that "in order to survive a motion to dismiss, a complaint must plead 'the facts comprising the cause of action . . . with sufficient specificity. Bald assertions and conclusory statements by the pleader will not suffice".
The trial court's initial dismissal of Mohiuddin's second amended Complaint was "without prejudice". Seven months later, Mohiuddin filed a fourth amended complaint renaming PHC. In turn, PHC filed another motion to dismiss which the trial court granted "with prejudice".
The Court of Special Appeals noted that the words "with prejudice" are ordered in cases where the dismissal is based on an appraisal of the substantive merits of the case and prohibits a refilling. The words "without prejudice" is more likely in cases where dismissal is based on some procedural glitch that does not engage the merits or res judicata and can be rectified such that it permits a refilling.
In addition, Maryland Rule 2-322(c) provides that "an amended complaint may be filed only if the court expressly grants leave to amend." Thus, whether a pleading may be amended is resolved by the trial court by explicitly stating within the four corners of the Order itself, "with leave to amend." Leave to amend is either expressly stated on the face of the order or it does not exist, there is no in-between. If the Order grants leave to amend, there is no final judgment and the case is not closed. By contrast, an order that does not contain "with leave to amend" closes the case finally and there is nothing to amend, unless the case is being kept alive by some other means. Accordingly, the Court held that in the absence of the trial court granting leave to amend, Mohiuddin had no entitlement to amend at any time, early or late. The requirement that there must be an express and unqualified grant of leave to amend within the four corners of the dismissal order is ironclad.
Posted by R. Anderson on 12/06/2010 at 04:51 PM
Maryland •
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Assumption of the Risk - Slip and Fall on Icy Sidewalk
In Mary Thomas v. Panco Management of Maryland, LLC, et al., ___________ Md. App. ____________ (Oct. 1, 2010), the Maryland Court of Special Appeals affirmed a ruling from the Circuit Court for Prince George's County, holding that, in a slip and fall case, a plaintiff can be held to have voluntarily assumed the risk of slipping on ice or snow even if the plaintiff has no alternative safe route to reach his or her destination, provided, however, that the plaintiff has some alternate safe course of action.
Ms. Thomas sued the owner and management company of her apartment complex for personal injuries that arose when she fell on black ice on the sidewalk in front of her apartment building and fractured her right leg.
In order to establish assumption of the risk, the defendant must establish that the plaintiff (1) had knowledge of the risk, (2) appreciated the danger of the risk, and (3) with this knowledge and appreciation voluntarily encountered the risk. At trial, Ms. Thomas testified that the sidewalk in front of her apartment did not get much direct sunlight and that she knew that when the snow and ice did melt in this area that water would flow onto the sidewalk, making it wet. Further, it was known to Ms. Thomas that when wet, icy conditions could develop on the sidewalk if temperatures fell below freezing. Ms. Thomas encountered icy conditions in the morning of the injury on her way to work. Ms. Thomas then encountered wet conditions two more times later in the day before the temperatures fell below freezing. Later that evening when Ms. Thomas left her apartment for a third time, ice had developed on the sidewalk and Ms. Thomas, who did not see the black ice slipped and fell and broke her leg. The trial court found that Ms. Thomas, based on bits and pieces of information that she possessed and gathered throughout the day as well as her experience at the apartment complex as a longtime resident, had knowledge of the risk that she might be stepping down upon ice and that a reasonable person in her position would have appreciated the danger of that action.
Ms. Thomas argued that even if she had knowledge of the risk and appreciated the risk, she did not voluntarily assume the risk since she had no alternative means of egress from her apartment to the parking lot. However, the Court opined that Ms. Thomas had alternatives, she could have called the apartment complex?s maintenance staff to put down salt, or she could have refused to take her granddaughter to church in the first instance knowing the sidewalks might be icy. Thus, in affirming the trial court, the Court of Special Appeals concluded that Ms. Thomas? actions would only be considered involuntary if she lacked the free will to avoid the situation. Accordingly, even though Ms. Thomas did not have an alternative safe path to her car, she did have a safe alternative course of action to not encounter the known risk, such that her decision to leave her apartment constituted voluntarily encountering the risk which satisfied the third and final prong.
Posted by Robert A. Anderson on 10/21/2010 at 01:23 PM
Maryland •
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In Maryland workers’ compensation claim, employer must show actual prejudice from late notice
In Melody Elste v. ISG Sparrows Point, LLC et al., ___Md. App.___, ___A.2d___(2009), Maryland's intermediate appellate court examined when an employer is "prejudiced" by an employee's failure to provide notice of an accidental injury within ten days of the injury's occurrence as required by Md. Code (2008 Repl. Vol., 2009 Supp.), secs. 9-704 and 9-706 of the Labor and Employment Article. The court determined that prejudice is established when an employer produces concrete evidence that indicates that the employee's failure to provide notice of his or her injury within ten days of the injury's occurrence caused actual harm to the employer's legal interests.
Melody J. Elste twisted her right knee on July 27, 2006 while working a safety shift at ISG Sparrows Point ("Sparrows Point"). Ms. Elste did not report her injury to Sparrows Point until 19 days later, on August 14, 2006, upon returning from a one week camping vacation. On September 9, 2006, Ms. Elste underwent knee surgery and on October 10, 2006, she filed a claim for workers compensation benefits.
The Workers Compensation Commission awarded Ms. Elste temporary total disability benefits. Sparrows Point sought judicial review of the Commission?s award in the Circuit Court for Baltimore City. During the jury trial for the matter, Ms. Elste moved for judgment at the close of Sparrows Point's case, and again at the close of all evidence, arguing that Sparrows Point had produced "no evidence whatsoever" that it was prejudiced by her failure to provide it with notice of her injury within ten days of the injury's occurrence. The circuit court judge denied the motions and the jury concluded that Ms. Elste had not given Sparrows Point timely notice of her injury. Ms. Elste filed a motion for JNOV, which was also denied. An appeal to the Court of Special Appeals ensued.
Before the Court of Special Appeals, Sparrows Point argued that it was prejudiced by Ms. Elste's failure to notify it of her injury within ten days of her accident because it was denied the opportunity to timely investigate the accident and to evaluate Ms. Elste's pre-vacation condition. The Court of Special Appeals rejected these arguments, holding that "an employee?s mere participation in [an] intervening activity, or an employer's inability to conduct an immediate investigation, cannot, by themselves, constitute prejudice." The court emphasized that under secs. 9-704 and 9-706 of the Labor and Employment Article, prejudice is established only when an employer offers specific evidence regarding how an employee's failure to provide notice of an injury harmed the employer's legal interests. The court noted that, in this case, such evidence could have included that a change had occurred in Ms. Elste's condition, the scene of the accident, or the memory of one of the witnesses. Due to the lack of such evidence, the Court of Special Appeals held that the trial court erred in denying Ms. Elste's motion for judgment and her motion for JNOV.
Posted by Mandy Wolfe on 11/02/2009 at 08:29 PM
Maryland •
Workers Compensation •
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