Exhibits to complaint, defendants - Insurance Coverage Blog

62. Defendants deny the allegations contained in Paragraph 62. Defendant, Scruggs
Law Firm, P. A. , has asserted in its Supplemental Demand for Arbitration fied with the American
Arbitration Association that plaintiff owes fiduciary duties to Scruggs Law Firm, P.A. arising
from plaintiff's representation of Scruggs Law Firm, P.A. in other litigation; and that plaintiff
has
breached those duties by disclosing andlor threatening to disclose privileged and confidential
information acquired during its representation of Scruggs Law Firm, P .A. for its own (il-gotten)
gain, and by using and/or threatening to use a twisted and false version of such privileged and
confidential information to harass, intimidate, threaten, and pressure Scruggs Law Firm, P.A. into
paying monies under the Joint Venture Agreement to plaintiff which plaintiff has not earned and
does not deserve. The proper remedy for plaintiff's breach of fiduciary duties is the disgorgement
of all fees paid to plaintiff by Scruggs Law Firm, P.A. This claim is subject to arbitration, but
Scruggs Law Firm, P. A. reserves the right to assert this claim as a counterclaim in this proceeding
in the (unlikely) event it is determined that said claim is not subject to arbitration. Scruggs Law
Firm, P.A. reserves the right to assert this claim as a counterclaim without waiver of its right to
arbitrate this claim and all of
plaintiff's claims and only as may be necessary to preserve its rights.
63. Defendants deny the allegations contained in Paragraph 63. Defendant, Scruggs
Law Firm, P.A., has asserted in its Supplemental Demand for Arbitration fied with the American
Arbitration Association that plaintiff owes fiduciary duties to Scruggs Law Firm, P.A. arising
from plaintiff's representation of Scruggs Law Firm, P. A. in other litigation; and that plaintiff has
breached those duties by disclosing andlor threatening to disclose privileged and confidential
information acquired during its representation of Scruggs Law Firm, P.A. for its own (il-gotten)
gain, and by using and/or threatening to use a twisted_and false version of such privileged and
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