Fields Howell News & Highlights

Fields Howell Recognized as Insurance Law Leader

2011-01-26T08:34:00.000-08:00

U.S. News & World Report’s Best Law Firm Ratings designated Fields Howell a Tier One (highest tier) Insurance Law firm. The publication’s rankings are based on surveys of thousands of law firm clients, leading lawyers and law firm managers, partners and associates, and marketing officers and recruiting officers.

Mike Athans, Matt Barrett and Jeff Kershaw represent Fields Howell on the Council on Litigation Management. Mike has been one of CLM's Georgia Chairs since the organization's inception three years ago, and he became the lead Georgia Chair in 2010. Mike was a speaker at the 2010 CLM annual conference, is a member of CLM's bad faith committee, and has taught CLM's claim handling and litigation management classes for insurance company professionals at Colony Specialty, Arrowpoint, Infinity, Merchant's and McGriff Seibels, among others. CLM is an alliance of corporations, insurance companies, law firms and service providers committed to furthering the highest standards of litigation management.

Bob McLaughlin, Emily Bramer and Nikki Baker received a plaintiff's verdict in a pro bono case last week.

2009-12-14T10:03:00.000-08:00

Bob McLaughlin, Emily Bramer and Nikki Baker received a plaintiff's verdict in a pro bono case last week. The case involved a lawsuit against one of four individuals responsible for beating up the plaintiff and breaking his jaw. The defendant refused to settle, arguing that he did not participate in the beating. The verdict for the plaintiff was $95,000, $75,000 compensatory damages and $20,000 punitive damages, after a two-day trial.

Fields Howell attorneys Richard Zelonka and Christy MacPherson recently obtained a victory on behalf of their restaurant client.

2009-11-23T12:13:00.000-08:00

Fields Howell attorneys Richard Zelonka and Christy MacPherson recently obtained a victory on behalf of their restaurant client in a slip-and-fall lawsuit in the State Court of Carroll County. In granting Richard and Christy’s Motion for Summary Judgment, the Court adopted their argument that the Plaintiff could not prove that, despite exercising ordinary care for her own personal safety, she lacked knowledge of a stack of bathroom mats due to the restaurant’s actions. The Court also agreed that the Plaintiff could not create a question of fact simply by submitting an affidavit contrary to her prior deposition testimony, and that any such conflict must be construed against her. The Court held that Richard and Christy had established Plaintiff’s knowledge of the mats by evidence in the record, to a level of being plain and palpable, and that the jury’s intervention was not required.

Fifth Circuit Holds that International Insurance Contracts are Subject to Arbitration Regardless of Individual States’ Laws

2009-11-18T14:12:00.000-08:00

The United States Court of Appeals for the Fifth Circuit held earlier this week that state law does not reverse-preempt the Convention on the Recognition and Enforcement of Foreign Arbitral Awards, a treaty requiring its signatories, including the United States, to recognize written agreements to arbitrate. At issue was a Louisiana statute providing that no insurance contract delivered in that state could deprive Louisiana’s courts of jurisdiction in any action against an insurer, a provision frequently cited by Louisiana courts in invalidating arbitration provisions in insurance contracts. The United States District Court for the Middle District of Louisiana had held that the McCarran-Ferguson Act, a federal law expressly leaving the regulation of insurance up to the states, required the application of Louisiana’s statute. The Court of Appeals disagreed, however, since the Act specifies only that no “Act of Congress” will supersede state law without addressing the effect of treaties.

The case is Safety Nat’l Cas. Corp. v. Certain Underwriters at Lloyds, London, No. 06-30262 (Nov. 16, 2009).

Chinese Drywall Presentation at 2009 FETTI Conference

2009-10-02T07:32:00.002-07:00

Matt Barrett and Jeff Kershaw discussed the insurance coverage implications of Chinese Drywall on Friday, October 2, 2009 at the 2009 FETTI Conference in Chicago. The National Forum for Environmental & Toxic Tort Issues (FETTI) is an organization that was created by the environmental sector of the insurance industry. Members are typically individuals, companies and firms actively engaged in the adjustment, settlement and defense of casualty or property claims arising out of environmental damage or exposure to toxic substances.

From 2004 through 2006, drywall manufactured in China was imported for residential construction projects. This “Chinese drywall” was used across the country but mostly in Florida, where there was a housing boom, and in Louisiana, in the aftermath of Hurricane Katrina. Thereafter, homeowners began complaining of foul odors, corrosion, and respiratory and other health problems that they attributed to the drywall. Although hard science regarding the causes of these issues or the drywall’s purported effects remains scarce, claims have be been made and lawsuits filed since reports began surfacing in late 2008. Matt and Jeff's presentation focused on coverage defenses available with regard to drwyall-related damages under commercial general liability, first-party, and pollution liability insurance polices.

For more information including a copy our paper titled "Chinese Drywall: Coverage Implications," please contact Matt Barrett at mbarrett@fieldshowell.com or (404) 214-1733.

Fields Howell attorneys Mike Athans and Matt Barrett received a favorable decision

2009-10-02T07:32:00.001-07:00

Fields Howell attorneys Mike Athans and Matt Barrett received a favorable decision from US District Court Judge Louis Sands on September 30, 2009, granting summary judgment to their clients, CNA insurance companies, in a construction defect insurance coverage Declaratory Judgment action in the Middle District, Georgia. Judge Sands ruled that alleged defective construction of apartment buildings in Columbus that resulted in settling, cracking and other alleged damage needing repair did not constitute an accident or occurrence under Georgia law. Therefore, the insurers did not have an obligation to defend or indemnify the insured general contractor that was sued by the property owner in the underlying lawsuit.

Jeff Kershaw recently won a victory on behalf of an engineering firm

2009-08-18T12:14:00.000-07:00

Jeff Kershaw recently won a victory on behalf of an engineering firm and its CEO in a professional malpractice case in the Superior Court of Fulton County. In granting Jeff’s Motion to Dismiss, the Court adopted his interpretation of Georgia law regarding the duties of professional engineers. Jeff successfully established that, under Georgia law, an engineer has no duty to examine setbacks or otherwise undertake land surveying work.

Four Litigators Join Fields Howell

2009-05-20T15:51:00.000-07:00

Four litigators recently joined Fields, Howell, Athans & McLaughlin LLP. Partner Mike Bruyere and Associates John Kane and Meghan Marino joined the firm from Locke Lord Bissell & Liddell LLP. Associate Christy MacPherson previously worked with Morris, Manning & Martin LLP.

Mike continues his commercial litigation and trial practice, representing businesses and insurers in product defect and consumer fraud class actions, pharmaceutical litigation, trade secret theft, unfair competition, restrictive covenant matters, securities and corporate governance cases, and business-to-business transactional disputes. John, Meghan, and Christy litigate complex insurance and business disputes.

Fields, Howell, Athans & McLaughlin LLP focuses on business litigation and complex insurance matters. Fields Howell litigates commercial, class action, and construction disputes and advises clients regarding coverage disputes involving general liability, first-party, professional liability, errors and omissions, environmental liability, and other insurance policies.

Fields Howell Obtains Summary Judgment in Negligent Inspection Case

2009-01-30T14:27:00.000-08:00

Fields Howell represented a national underwriting inspection company, in a recent victory in the United States District Court for the Western District of Missouri. The Insurer filed suit against the inspection company after the insurer failed to avoid coverage for a fire loss claim through a declaratory judgment action against its insured, the owner of a hotel. In the declaratory judgment action, the insurer argued that it had no duty to pay the claim because its insured failed to maintain a “central station fire alarm.” The trial court rejected the insurers arguments and granted summary judgment to the insured regarding coverage. The insurer subsequently settled for amounts significantly in excess of the policy's limits.

The inspection company performed an inspection of the hotel at the request of the insurer's wholesale broker, months before the fire. In its lawsuit against the inspection company, the insurer sought to recoup its settlement with the insured by alleging that the inspection company’s failure to report the absence of a “central station fire alarm” prevented the insurer from cancelling the insured's policy before the fire. The insurer also alleged that the inspection company failed to report numerous other conditions that would have caused it to cancel the insured's policy.

The inspection company filed a counterclaim for indemnity based on an indemnity provision in its inspection report and moved for summary judgment. The insurer filed a cross-motion for summary judgment, arguing that the alleged omissions or errors in the inspection company's report were material to its underwriting and prevented policy cancellation. The insurer also argued that the indemnity provision was unenforceable because it was ambiguous and not part of the contract between the insurer's wholesale broker and the inspection company. The trial court granted the inspection company's Motion for Summary Judgment, finding that many of the alleged conditions did not exist, that other conditions were not material, and that the inspection company’s indemnification provision was an enforceable contractual term that the insurer breached by filing suit against the inspection company.

The trial court’s ruling on the inspection company’s motion for an award of the attorney’s fees and litigation expenses incurred as a result of the insurer’s breach of the indemnity provision is currently pending. Paul Fields and Ryan Fellman lead the representation of the inspection company with the assistance of paralegal Tricia Arnold.

Georgia Supreme Court Broadly Construes Insurance Policy Pollution Exclusion

2008-10-07T08:07:00.000-07:00

Many commercial general insurance (“CGL”) policies exclude coverage for bodily injury or property damage caused by exposure to a “pollutant.” On September 22, 2008, the Supreme Court of Georgia held that carbon monoxide is a “pollutant” as the term is often defined in CGL policies and that coverage for claims related to carbon monoxide exposure are , therefore , barred by the pollution exclusion . The case, Reed v. Auto-Owners Ins . Co . , No. S07G1768, 2008 WL 4286606, at *2 (Ga. Sep. 22, 2008), should bolster previous Georgia case law that broadly construes the term “pollutant” according to the plain terms of CGL policy language in applying pollution exclusions.

In Reed, the plaintiff, a residential tenant, sued her landlord for carbon monoxide poisoning; the landlord subsequently made a claim with his insurance company under a CGL policy. The insurer filed a declaratory judgment action, seeking a declaration that there was no coverage in light of the policy’s pollution exclusion. When the trial court denied the insurer’s motion for summary judgment, the insurer appealed. The Court of Appeals reversed.

In affirming the Court of Appeals’ reversal, the Supreme Court of Georgia noted that “the very basis for Reed’s lawsuit is her claim that the release of carbon monoxide gas inside the rental house ‘poisoned’ her ….” Thus, “the plain language of the pollution exclusion clause excludes Reed’s claim … from coverage under the CGL policy.”

Justice Hunstein, joined by Justice Carley, dissented, arguing that the insured under a CGL policy would not reasonably expect that the policy’s pollution exclusion would apply to injuries caused by carbon monoxide. Construed to include carbon monoxide, Justice Hunstein argued, the pollution exclusion is rendered unreasonably broad given the inherent ambiguity of the terms used to define “pollutant”. The Reed decision, however, is one in a long line of Georgia cases that have upheld pollution exclusions as clear and unambiguous. E.g., Am. States Ins. Co. v. Zippro Const. Co., 216 Ga. App. 499, 455 S.E.2d 133 (1995) (ruling on asbestos); Truitt Oil & Gas Co., Inc. v. Ranger Ins. Co., 231 Ga. App. 89, 498 S.E.2d 572 (1998) (ruling on gasoline); Perkins Hardwood Lumber Co. v. Bituminous Cas. Corp., 190 Ga. App. 231, 378 S.E.2d 407 (1989) (ruling on smoke).

Eleventh Circuit Rules In Favor of International Insurer

2008-08-29T08:10:00.000-07:00

FHAM represented Alea London Limited, a United Kingdom based insurer, in its recent appellate victory in the United States Court of Appeals for the Eleventh Circuit. This appeal involved the extent of an insured’s obligation to provide timely notice of a potential claim, when the insurer’s address was not listed in the policy.

Alea’s insured contacted his insurance broker to report a claim, after he witnessed a contractor fall off of a multi-story extension ladder. The contractor was in a coma for several months, but the insured’s broker never reported the claim to Alea.

Twenty-three months later, after the insured was served with a lawsuit, the claim was first submitted to Alea for a defense and indemnity up to Alea’s significant policy limits. Alea provided a defense, subject to a reservation of rights, and immediately filed a declaratory judgment action in the United States District Court for the Northern District of Georgia to determine its rights and obligations under the policy. Although the insured asserted that the policy had been issued without any contact information for Alea, the District Court granted Alea’s Motion for Summary Judgment finding that the absence of contact information did not transform the broker into Alea’s agent for notice of a potential claim and that the delay in providing notice was unexcused as a matter of law.

The insured appealed to the Eleventh Circuit arguing that the absence of specific contact information waived Alea’s right to contest the sufficiency of the notice. In a Per Curiam decision, the Eleventh Circuit rejected the waiver argument and affirmed the judgment in favor of Alea.

Alabama sets new timetable for statute of limitations in toxic exposure lawsuits

2008-02-01T08:29:00.000-08:00

The Supreme Court of Alabama has ruled that the two-year statute of limitations for personal injury claims will now begin when the alleged injury manifests itself as a present injury. This will likely result in a sharp increase in the number of toxic tort suits filed in Alabama.

For 29 years Alabama has followed the rule set forth in Garrett v. Raytheon. Garrett v. Raytheon Co., 368 So.2d 516 (Ala. 1979). The Garrett Court held that a personal injury action based upon exposure to hazardous chemicals accrues on the date of last exposure to the chemicals. Id. Thus, as many toxic tort injuries do not manifest themselves in a form that can be diagnosed to a medical degree of certainty within two years, many cases were time-barred by Alabama’s two year statute of limitations on personal injury claims. Ala. Code § 6-2-38(1) (1975).

In a recent 5-4 decision that is pending publication, the Supreme Court of Alabama specifically overruled Garrett. In Griffin v. Unocal Corporation, et al., the Court ruled that "a cause of action accrues only when there has occurred a manifest, present injury." Griffin v. Unocal Corporation, et al., 2008 WL 204445 (Ala.), quoting the dissent in Cline v. Ashland, Inc., et al., 2007 WL 30070 (Ala.). The Griffin case involved a worker in the rubber industry who was allegedly exposed to benzene from 1973 through 1993. The worker developed what is alleged to be benzene related leukemia in 2003. The trial court dismissed the case as violative of Alabama’s statute of limitations. The Alabama Supreme Court overruled the trial court and overturned the Garrett line of cases. As a result, plaintiffs will now have two years to file suit after a medical problem becomes apparent, such as after a doctor’s diagnosis.

The Griffin ruling will likely lead to a significant increase in the numbers of toxic tort cases filed in Alabama. The decision comes after the election in 2006 of a new Supreme Court Justice, Sue Bell Cobb. Cobb is the sole Democrat on the Court and hers was the deciding vote.

Underwriters Win Significant Victory Over Beazer Homes

2007-10-30T09:11:00.000-07:00

FHAM represented Certain Underwriters at Lloyd’s, London in their recent victory over Beazer Homes in the Superior Court of Fulton County. Beazer is a Fortune 500 Company and is one of the top residential homebuilders in America. Beazer filed suit against Certain Underwriters contending that its insurance broker successfully negotiated an endorsement to add three newly acquired companies to Underwriters’ excess liability insurance contract.

Certain Underwriters moved for summary judgment because a condition of the endorsement to add the newly acquired companies was for the parties to agree to the wording of a known loss exclusion, which was never done. Beazer contended that by considering several documents the court should find an enforceable written contract existed and that any ambiguity as to the wording of the known loss exclusion in that contract should be construed against Certain Underwriters.

The trial court granted Certain Underwriters’ Motion for Summary Judgment, finding that Beazer and Underwriters attempted for several years to agree to language for the wording of a known loss exclusion, and despite repeated attempts, the parties were unable to agree to the language of the exclusion. The court stressed that the testimony from Beazer’s insurance broker who negotiated the coverage showed that the parties never agreed on the wording of a known loss exclusion. In addition, Beazer’s insurance brokers who negotiated the coverage testified that there was no way for this Court to know the wording of the known loss exclusion to be agreed by the parties. Thus, the trial court found there was no written agreement to a known loss exclusion.

Bob McLaughlin and Terry Howell led the representation of Underwriters, with the assistance of several associates, including Andy Diamond and Jonathan Kramer, and paralegals Pam Bader and Jennifer Hronek.

FHAM Wins Professional Liability Case...

2007-10-30T09:04:00.000-07:00

FHAM Wins Professional Liability Case in Which the Georgia Court of Appeals Decides Issue of First Impression

In a case of first impression in Georgia, the Georgia Court of Appeals has decided that a professional liability policy does not cover an attorney’s alleged liability for breaching a fee-splitting contract. Garland v. American Safety Casualty Insurance Company, 2007 WL 2305475 (Aug. 14, 2007). FHAM attorneys, Terry Howell and Jonathan Kramer, represented American Safety against a suit by an Atlanta criminal defense attorney, demanding that American Safety reimburse him under its professional liability policy for over $100,000 in defense costs expended in winning a Florida case.

In the underlying lawsuit, a Florida attorney asserted that the Atlanta attorney owed compensation to the Florida attorney under an alleged oral fee referral contract. American Safety denied coverage because the underlying lawsuit did not involve performance of legal services as required by the policy and because the exclusion in the policy for damages arising from the restitution of fees applied. The Atlanta attorney sued American Safety, arguing that American Safety had wrongfully refused to defend him. FHAM convinced the trial court to dismiss the suit because there was no possibility of coverage under the professional liability policy and therefore no duty to provide a defense.

The Georgia Court of Appeals affirmed, holding:

Here, given the fact that the Florida attorney’s lawsuit against Garland and his firm
involved the alleged breach of a fee-splitting agreement incidental to the firm’s business as a law firm, the claim did not arise from Garland’s or his firm’s acts or omissions in rendering professional services as lawyers and was not covered by the policy issued by American Safety.

2007 WL 2305475, *3. The Court of Appeals relied heavily on the fact that many courts in the United States have held that contractual fee disputes do not constitute the rendering of professional services. Id. at *1.

FHAM's In-Depth Knowledge of The London Market

2007-07-23T12:06:00.000-07:00

FHAM remains committed to the professional development of its attorneys and its relationship with the London insurance market. As recognized by United States’ courts, the Lloyd’s, London insurance market in particular is unique, based on age-old customs that differ from traditional American business practices. E.R. Squibb & Sons, Inc. v. Accident & Cas. Ins. Co., 160 F.3d 925, 928-29 (2d Cir. 1998). “As all know, Lloyd’s is not, in reality, an insurance company in either the English or the American sense. It bears little resemblance to a typical corporate insurer.” Syndicate 420 at Lloyd’s London v. Early American Ins. Co., 796 F.2d 821, 824 (5th Cir. 1986).

For that reason, FHAM prides itself on its specialized knowledge of the London market, which can only be developed through years of practice. FHAM holds regular meetings to examine and discuss the latest developments in the market. As part of its attorney training program, young associates also are taken on market trips to see first-hand how the market works.

Recently, FHAM has started a secondment program with Lloyd's Syndicates. Through this program, FHAM attorneys spend several months living and working in London for the firm’s clients. As a secondee, FHAM lawyers are readily available to meet with clients in person at a moment's notice. In addition to providing the firm with a local representative to handle pressing matters, this enables the firm to stay on the cutting edge of market developments, while providing its attorneys with training and skill that would otherwise take years to develop. The resulting effect is that all FHAM lawyers, not just the partners, are knowledgeable about their clients' workings and concerns.

Recent Louisiana Flood Decisions

2007-05-08T15:34:00.000-07:00

The Standard Flood Exclusion

FHAM attorneys are defending multiple Hurricane Katrina coverage lawsuits in the Gulf Coast region in federal and state courts. There have been a number of new developments in the area of coverage law regarding the standard flood exclusion included in most homeowner’s policies. A major issue has been whether the standard flood exclusion, upheld by the Louisiana courts for eighty years, bars recovery for flood caused by so-called manmade events such as levee failure. Judge Duval of the Unites States District Court for the Eastern District of Louisiana recently held that the flood exclusion was ambiguous with respect to flood caused by alleged levee failure due to negligent levee design.

By way of a brief background, the standard flood exclusion was traditionally upheld under Louisiana law. See Morehead v. Allstate Ins. Co., 406 F.2d 122 (5th Cir. 1969) (holding exclusion for loss “caused by, resulting from, contributed to or aggravated by . . . flood, surface water, waves, tidal wave . . . .” upheld where house floated from its piers and settled on the ground); see also Milton v. Main Mut. Ins. Co., 261 So.2d 723 (La. Ct. App. 1972) (upholding similar flood exclusion where car was submerged under rising waters caused by Hurricane Betsy); see also Travelers Indem. Co. v. Powell Ins. Co., No. 95-4188, 1996 WL 578030, at * 1 (E.D. La. Oct. 4, 1996) (concluding that the exclusion barred coverage of golf carts flooded by torrential rains in New Orleans because the exclusion “unequivocally” and “unambiguously excludes coverage for flood damage . . . .”).

Despite the established body of Louisiana law upholding the flood exclusion, Judge Duval held that the exclusion was ambiguous because it did not distinguish between “man-made” and “natural” flood, and, therefore, the wording failed to exclude man-made flood resulting from the alleged negligent design of the levees. In re Katrina Canal Breaches Consol. Litig. (E.D. La. Nov. 27, 2006). This ruling has been appealed to the 5th Circuit Court of Appeals, and oral argument is scheduled for 4 June 2007. (At least one Louisiana state court has agreed with this holding, and that decision has also been appealed. Historic Restoration Inc. v. RSUI Indem. Co. and Essex Inc. Co., No. 06-4990, Div. D. (Civ. Dist. Ct. for the Parish of Orleans, Dec. 5, 2006). FHAM attorneys are monitoring the appeals, and we shall periodically update the Blog with current developments.

Flood Policy Recovery Offset

In a series of very recent decisions, the United States District Court for the Eastern District of Louisiana resolved an important question regarding another flood issue: whether insureds may recover under both their flood policies and standard homeowner’s policies for the same damage. The answer is “no.” In Esposito v. Allstate Ins. Co., No. 06-1837, 2007 WL 1125761, at *1 (E.D. La. April 16, 2007), Allstate denied recovery to a homeowner who sought policy limits under his wind policy because he was already compensated for the loss by his flood carrier. The insured’s property was flooded for approximately two weeks by six feet of water. The Court ruled that such an additional recovery contradicted the insured’s position regarding flood damage and would exceed the value of his property.

Allstate tendered payment for some wind damage and contents damage with respect to the second floor, but filed a Motion for Summary Judgment contending the insured should be estopped from asserting that wind caused all of his losses after having received funds for the same loss from his federal flood policy. In the alternative, Allstate argued that any further recovery must be offset by the flood recovery because the Plaintiff was limited to the actual cash value of the home.

The District Court acknowledged a recent decision, Weiss v. Allstate Ins. Co., No. 06-3774, 2007 WL 891869, at *1 (E.D. La. Mar. 21, 2007), rendered by Judge Vance of the Eastern District, in which a similar motion by Allstate was denied. In that case, Judge Vance determined issues of material fact pertaining to the value of the property and regarding whether plaintiffs had admitted that their property was damaged solely by water precluded summary judgment. Id. at *2-3. In reaching her decision to deny summary judgment, Judge Vance ruled that a plaintiff whose property sustains damage from flood and from wind can recover for his segregable wind and flood damages except to the extent that he seeks to recover twice for the same loss. Weiss, 2007 891869, at *2; see also Wellmeyer v. Allstate Ins. Co., No.06-1585, 2007 WL ___, at *1 (E.D. La. April 26, 2007).

Based on the reasoning in Weiss, the Esposito Court opined that the insured could recover any previously uncompensated losses covered by his wind policy, and which, when combined with his flood insurance recovery, did not exceed the value of his property. The Court held that the insured could not obtain a windfall double recovery by re-characterizing as wind damage those losses for which he had been compensated already by his flood coverage:

The NFIP [National Flood Insurance Program] did not erroneously make payments to Plaintiff for flood losses to his home. Plaintiff sought those payments and he obtained them by convincing FEMA that his losses were caused by flood and covered by his flood policy. Plaintiff has now been compensated for those losses based on the statements and information that he provided to FEMA. For purposes of the instant suit this Court will not allow Plaintiff to cavalierly repudiate those prior statements while nevertheless retaining the funds that he received based on those same statements (emphasis in original).

Accordingly, the Court granted summary judgment to Allstate, denying any further recovery to Plaintiff. These cases are fact intensive, and recovery will depend heavily on the nature of the insured’s recovery from his flood insurer and on the value of the property.

Please let us know if you would like a copy of the cases. We continue to monitor the latest rulings from Gulf Coast courts.

FHAM Launches Redesigned Web Site featuring a New Logo

2007-04-27T10:41:00.000-07:00

On the occasion of our third anniversary, FHAM announces the launch of our redesigned web site featuring a new logo. In three exciting years we have grown from seven attorneys and three staff members to twenty-one attorneys, four paralegals, and sixteen staff members. We would like to thank our clients for their terrific support. We look forward to continuing to provide them with the highest caliber of service. Please check this site periodically in the future for articles of interest relating to the work we do at Fields, Howell, Athans & McLaughlin.