Law Firms

Morgan & Morgan won't give 'one single inch' to insurance carriers on continuances and courtesies

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A sign of Morgan & Morgan in Orlando, Florida. Image from Shutterstock.

Personal injury law firm Morgan & Morgan is drawing a line in the sand after Republican Florida Gov. Ron DeSantis signed a sweeping tort reform measure into law.

Morgan & Morgan will not be agreeing to continuances, extensions and other courtesies, said Reuven Moskowitz, the firm’s chief operating officer, in an internal memo sent to attorneys March 24, the same day that DeSantis signed the bill.

Matt Morgan, the firm’s managing partner, sent the memo to the ABA Journal at its request. Morgan also forwarded to the Journal a second memo in which he cautioned that all lawyers must observe the rules of professional conduct.

Here is the first memo, which has also been published by Above the Law, on Twitter and by Florida Politics:

“Good morning PI lawyers across the country!

As we enter this new era, I want to make it unequivocally clear that we will not be giving an inch to carriers ever again.

Not one inch.

Specifically, as a matter of policy we will not be granting any extensions of any sort moving forward for any reason.

They can figure it out or file a motion.

Under no circumstances will we be agreeing to any continuances, discovery extensions, or request to extend deadline to answer complaints.

Red line rules.

It will be a serious internal offense if we find any courtesies being extended to the insurance industry.

Including cases filed prior to March.

No discovery extensions.

No matter the circumstances.

We may want to help the human being defense attorney because we know them and maybe like them, but we will not because they work for an enemy who is heartless and ruthless.

The enemy who just tried to kill us in FL.

They work for the enemy who would like nothing more but for you to be unemployed.

We work for the people.


They tried to take from the most vulnerable people and consequently, from your families.

No extensions for responses to our complaints.

If there are extenuating circumstances that would benefit our client only, please reach out to Matt or Jon Smith for prior approval.

As a blanket rule we will be giving not one single inch.


Morgan added this clarification in this firmwide memo March 28:

It “goes without saying that all attorneys and team members are required to follow the rules of professional conduct and civil procedure in their state to the letter of the rule/law.

All lawyers in their individual states are to make the legal decisions as requests come to their attention within their own discretion. These decisions are made on a case-by-case basis.

These decisions should be informed by our collective knowledge of the insurance industries practices. As many of you know, the insurance industry makes at least half of their profits on the ‘float.’ Google it please if you have not heard of this before. What this means is carriers take the money they owe our clients and invest it in the markets instead of paying our clients timely. The longer the money stays in the markets, the more interest on the money they make. This is why insurance companies drag out our cases for as long as they can. Our clients need their money now to put their lives back together. Our clients hire us to recover the money owed to them as quickly as possible so they may move on with their lives.

In my opinion, we should not be helping the insurance companies profit by delaying justice for our clients at scale. But as stated above, every circumstance is unique and should be evaluated by each individual attorney in accordance with the rules of professional conduct and the rules of civil procedure in their state. Each decision should be guided by the one question which informs everything we do for the people at our firm across the country: ‘What is in the best interests of my client?’”

DeSantis said he was signing the tort reform bill to stop the state from being a “judicial hellhole,” Law360 previously reported.

Provisions of the law:

    • Repeal one-way attorney fees, which allowed plaintiffs to recover reasonable attorney fees when they receive any award.

    • Eliminate Florida’s comparative negligence rule, which allowed plaintiffs to recover damages even if they are primarily at fault. Now, plaintiffs who are more than 50% at fault won’t be able to recover damages.

    • Shorten the statute of limitations in injury cases from four years to two years.

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