Affidavit from former Unum Provident employee

UNITED STATES DISTRICT COURT
DISTRICT OF MAINE

Daniel Donatelli, Plaintiff vs. UNUMPROVIDENT CORP., Defendant
Civil No. 04-1-P-S

AFFIDAVIT OF DANIEL DONATELLI

NOW COMES Daniel Donatelli and hereby states as follows under oath:

  1. My name is Daniel Donatelli. I am 18 years of age or older and believe in the obligation of an oath. The facts stated below in this affidavit are based on my personal knowledge.
  2. I was hired by Unum as a Disability Benefit Specialist to process long term disability claims. Disability Benefit Specialists at Unum had authority to make decisions on claims.
  3. After Unum’s merger with Provident, I became a customer care specialist and later was transferred to the Cardiac Psych Unit. Customer Care Specialists at UnumProvident did not have authority to make decisions on claims including approval, denial, and settlement. Our role became primarily processing and not managing.
  4. I did not begin working in the Cancer Unit until after February 25, 2002.
  5. While working in the cancer unit, Dennis Hersom told me that I would not survive a performance management program regardless of any improvement that I made with my work performance. Therefore, I resigned.
  6. While working in the Cardiac Unit and the Cancer Unit, I had some ethical and moral concerns regarding claims not being paid properly due to the pressure to meet quotas for closing claims.
  7. While I was at Unum, Unum provided insurance policies for employee sponsored plans, union or employee organization sponsored plans, employer sponsored plans, church plans, government plans, and many individual disability policy contracts.
  8. There was at least one individual Customer Care Specialist in my Cardiac Psych Unit, as well as an individual in my Cancer Unit, that was responsible for handling claims under individual disability insurance policies issued by Unum.
  9. I understood that all of these policies were subject to the same claims handling process and procedures. When I expressed concern about how the claims were handled, I was expressing concern for all claims and not just those on my caseload.
  10. I personally handled processed claims under church plans (for example, priests) and government/school plans (for example, teachers).
  11. Advance pay and closure was a way of closing claims based on a hypothetical ramp up of hours that was established by a customer care specialist or a vocational rehabilitation consultant. It was also based on an opinion from a UnumProvident doctor who made a determination of what the claimant was capable of doing. I believe that the advance pay and closure procedure is illegal because it could result in a claimant being subjected to higher scrutiny by UnumProvident if the claimant reopened his or her claim for benefits after a period of advancement has lapsed. Because the claimant had no right of appeal, and the claimant was not notified in advance, the claimant would be subject to higher scrutiny thereby misleading the client into agreeing to take an advance pay and close.
  12. The advance pay and close was regularly misused as a profit technique for Unum to free up reserves attached to each claim. For example, if we were running behind on projections to meet quotas for the month, we would be required to go back and look up part-time people that we could either close out through denial or through advance pay and close. Although advance pay and close was supposed to be with insured consent, often we were required to pressure them over and over again to accept an advance pay and close. Usually using advance pay and close had the effect of literally badgering an insured to go back to work. We were basically instructed to tell the insured that we expected them to be back to work in 30 days, “here’s your check.” Often, we would be required to apply this pressure even if the insured did not feel they were ready or able to return to work full-time. Rather we were required to use Unum medical staff to push the issue.
  13. I believed and reported to my supervisor that I thought the Defendant was misrepresenting policies and plan benefits to airline pilots and truck drivers in order to sell them policies. These people were lead to believe that the policies would cover them if a health condition made them unable to do their job, including maintenance of their license. However, the actual policies sold by Defendant included provisions that denied benefits if Unum doctors determined that the insured was physically able to perform the job requirements- even if those people were unable to get medical clearance from the FAA or state and federal licensing agencies to reinstate their license. I believed these activities were in violation of state and federal regulations.
  14. I also reported to my supervisors that Defendant participated in and engaged in phony round table discussions as a way to put on a show for potential customers that were receiving guided tours of the Unum Provident building. I believe this practice to be misrepresentation in order to sell policies, when, in fact, the round table discussions were faked and did not represent what the actual round table discussions were like. Actual round table discussions were geared toward speeding up resolution and closure of a claim. Phony round table discussions were meant to leave the potential customers to believe Defendant engaged in intelligent and objective round table discussions with regard to each claims. Not all claims went to roundtable.
  15. I was, at times, asked to miscode claims or to manipulate the time a claim was coded in order to manipulate reserves. I was asked to do this by Cynthia Bellefountaine, Dennis Hersom, and on occasion, Steve Leask.
  16. Cynthia Bellefountaine and Dennis Hersom, my managers, told me that the miscoding or manipulation of the time frame of coding a claim would have a direct impact on our reserves.
  17. I was pressured to close claims to meet quotas. The pressure would include claims denials based on the wording of medical information being changed. This change could result in an immediate denial of a claim. I believe that the rush to deny a claim by changing medical information was an improper handling of a claim.
  18. I felt pressure to close a claim by coding improperly. I was instructed to do this by my superiors. I believe this to be an improper or fraudulent practice with regard to handling claims.
  19. I was never notified by Unum or UnumProvident that I maintained any type of fiduciary status with regard to contracts or policies at Unum that were subject to ERISA. I was not a plan participant or beneficiary with regard to any of the complaints to which I complained.
  20. I resigned my employment at UnumProvident, in essence, in lieu of being fired. I was told by my supervisor that I would basically be given a 60-day performance management program or to resign. He made clear that I would not survive a performance management program regardless of any attempts I made, or improvement of my numbers. Mr. Hersom warned me that “I will not be able to give you a positive reference. You do not want a bad evaluation in your file.”
  21. I was concerned that claims are not being paid appropriately, as a result of the pressure to close claims in the Cancer Unit. Whether or not an individual claimant met the elimination, must be decided by interpreting the terms of the “contract.” Since UnumProvident handled individual disability contracts, as well as group plans, sometimes the elimination period would have to be decided by interpreting the terms of an individual contract.
  22. Some doctors and nurses had policies administered and/or sold through UnumProvident that provided benefits to them if they could not work on their own occupation. I understood that certain categories of nurses and doctors, such as emergency room personnel, worked in a very specialized and niche field within the industry. I based this conclusion on information provided by the insured’s. Also based on occupational descriptions provided by the employers and nurses/doctors, I understood that an emergency room nurse who was medically disabled from working in that occupation, would likely not have the training and transferable skills and qualifications to work outside of such a position, such as in an office environment or a consultant environment. However, Unum would deny these claimants benefits if Unum determined that they perform a less strenuous nursing position, even if they were not qualified for the position and had no chance of ever obtaining such a position.
  23. Often we were behind schedule in meeting our team quota for claim closures, the consultants and managers would pressure us to find other additional claims to close. One pressure to deny claims had to do with the wording in medical reviews. Often we would be asked to have the wording in medical reviews manipulated so that a denial could be made immediately. This caused us to rush and deny a claim before medical information was actually sufficient to make a good faith determination.
  24. Another tactic that Unum took when our team was falling behind in out quota, was to send us back and go through all files for a sort of “round up,” looking for loopholes or technicalities in the contracts or anything else that would help close the claim. Sometimes they would set aside a Saturday, requiring all Customer Care Specialists to come in and do a sort of “round up” for claim closures. I believed these tactics would result in some claims being closed prematurely.
  25. I filed a complaint against UnumProvident for whistle blowing before the Maine Human Rights Commission. I did not make any request for damages with regard to that complaint.
  26. Approximately a month before Hersom approached me to tell me that my job was on the line, I received my annual performance appraisal. Although the performance appraisal had some coaching comments, the performance appraisal reviewed my performance for the year as consistently meeting all goals and standards.
  27. I had no connections with the state of New York. During the relevant time frame, I never went to the state of New York. My deposition was taken here in Maine, my employment took place all here in Maine, and my entire relationship with Defendant took place here in Maine. I received, and read in Maine, a copy of the letter sent by Mr. White on November 6, 2002 to Mr. Gelber. I was embarrassed and humiliated by the false tone and nature of the letter.
  28. I requested, through counsel, that Unum retract the letter that it sent to CBS News, but Unum refused.

Dated: 9/17/2004

STATE OF MAINE
KENNEBEC, S.S. Dated:
9/17/04
Personally appeared the above-named Daniel Donatelli and swore to the truth of the foregoing statements to the best of his knowledge and belief.


Did you find this helpful?
Unhelpful (0)

Resources to Help You Win Disability Benefits

Disability Benefit Denial Options
Unum Disability Denial

Let’s discuss your case your Unum disability denial.

Unum Disability Denial

Submit a Strong Unum Appeal Package

We work with you, your doctors, and other experts to submit a very strong Unum appeal.

Unum Disability Appeal

Sue Unum

We have filed thousands of disability denial lawsuits in federal Courts nationwide against Unum.

Unum Disability Lawsuit

Protect Your Benefits
Get Your Unum Disability Application Approved
We help claimants throughout the entire application process.

Learn more

Prevent a Unum Disability Benefit Denial
We manage every aspect of your disability claim following claim approval.

Learn more

Negotiate a Unum Lump-Sum Settlement

Our goal is to negotiate the highest possible buyout of your long-term disability policy.

Learn more

Unum Reviews
(642)

Policy Holder Rating

1.6 out of 5
Read 60 reviews
0%would recommend
5
0%
4
0%
3
1%
2
55%
1
43%
Timely Payments
1.8out of 5
Handling Claim
2.1out of 5
Customer Service
2.1out of 5
Dependable
2.1out of 5
Value
1.9out of 5
Showing 8 of 642 Reviews
Unum

Low payments

Reviewed by Dorothy on November 30th 2023   Verified Policyholder | November 2023 date of disability
I was injured at work. I did house keeping in a hospital. I tore just about everything imaginable in my knee. I was let go from my job, because I was no longer able to do ... read more >
Unum

They closed my claim and I have been without income since they closed it

Reviewed by Mary C. on November 8th 2023   Verified Policyholder
Went off work on 9/26/22 due to back issues. Applied for Short Term Disability. On Jan 2023 switched over to Long Term Disability and Unum had me to apply for Social Secur... read more >
Unum

I feel like Unum is giving me the runaround!

Reviewed by Rachelle H. on May 11th 2022   Verified Policyholder
I have contacted UNUM multiple times since I’ve needed them. I feel like they are giving me the runaround! Please help!
Reply
Sent on May 11th 2022 by Attorney Stephen Jessup

Rachelle, the law provides certain timelines and deadlines with which to provide information or decisions. Please feel free to contact our office to discuss your situat... read more >

Unum

Unum terminated my benefits with no warning

Reviewed by K. Potter on September 9th 2020   Verified Policyholder
I was told I was covered with Unum through my employer (continuum). I got an email today for my termination, no prior talks of infractions with attendance, no warnings, no... read more >
Reply
Sent on September 9th 2020 by Attorney Stephen Jessup

K. Potter, termination as in your employment was terminated or a disability claim was terminated? If your employment was terminated and you had not filed a claim for di... read more >

Unum

I've been trying to care care of my Unum benefits for over a year. They’ve been so rude

Reviewed by Tracey W. on August 30th 2020   Verified Policyholder
I have been trying to take care of my Unum benefits for over a year. I’ve called and back in November I did appeal letter, they say they never received. I did everything... read more >
Reply
Sent on August 30th 2020 by Attorney Gregory Dell

Tracey, I am sorry to hear of your issues with Unum. We would love to learn more about your claim to see if we can get Unum to pay or if we can sue them with you. Pleas... read more >

Unum

I've paid for STD for 20+ years. Now, I'm actually sick and can't get paid

Reviewed by Natalie on June 29th 2020   Verified Policyholder
My employer uses unum for short-term disability. I was hospitalized back on june 13 and discharged on june 25. I was admitted for double pneumonia and hypoxia, which I end... read more >
Reply
Sent on June 29th 2020 by Attorney Rachel Alters

Natalie, hopefully your claim will be approved. If they deny the STD claim then you will need to appeal the determination.

Unum

Unum thought I was fine to work. I wasn't

Reviewed by Elizabeth L. on May 21st 2020   Verified Policyholder
48 yoa dentist POTs Dx aug 22. Attempted to return to work initially but got sick. Was going to go back 2 days/wk in September but could not. Then did go back part time as... read more >
Reply
Sent on May 21st 2020 by Attorney Stephen Jessup

Elizabeth, please contact our office to discuss the denial of your claim and your rights to pursue legal action against Unum.

Unum

Unum has made me feel like a criminal

Reviewed by Kevin on February 6th 2020   Verified Policyholder
Hi, I am currently receiving LTD from UNUM. I used to work as a Radiologist Tech at Vanderbilt Medical Center in Nashville, TN. for about 10 years. Than I started having g... read more >
Reply
Sent on February 6th 2020 by Attorney Gregory Dell

Kevin, I am sorry to hear all that you are going through and the stress this is causing you. The policy governing your claim likely does allow Unum to conduct an in-per... read more >

Answered Questions by Our Lawyers
(98)
Showing 8 of 98 Answered Questions

Q: Does Unum stop paying when you retire and or if you qualify for Social Security Disability?

Answered on April 16th 2024 by Attorney Gregory Dell
A: In most group Unum disability disability policies a retirement benefit that is funded by an employer and ssdi ... Read More >

Q: Can receiving a Unum group LTD benefit settlement lower my SSDI benefit?

Answered on March 29th 2024 by Attorney Gregory Dell
A: Jeff,The acceptance of a Unum Lump Sum Buyout offer should not reduce your ssdi benefit. You should contact ... Read More >

Q: Do we have any legal action against Unum?

Answered on January 15th 2024 by Attorney Alex Palamara
A: I am sorry to hear of Unum’s actions here and how they have treated your claim, especially in their long del... Read More >

Q: Is it normal for “UNUM” to ask for a police report?

Answered on January 15th 2024 by Attorney Alex Palamara
A: Derrick, a simple answer to your question is Yes, if there was some sort of MVA accident which caused or contr... Read More >

Q: Unum stopped my COLA benefits at age 65

Answered on December 19th 2023 by Attorney Rachel Alters
A: Unum policies usually only pay COLA increases until you turn 65 even if the policy pays longer. Read More >

Q: Survivor's benefits

Answered on December 15th 2023 by Attorney Gregory Dell
A: Cindy: A few things come to mind. Your disability policy will have a section called deductible sources of inco... Read More >

Q: FMLA and my LTD claim

Answered on December 6th 2023 by Attorney Gregory Dell
A: Unum doesn’t consider FMLA as they only care if you meet the terms of your disability policy with Unum. Read More >

Q: Is the recipient responsible for overpayment when they had nothing to do with the reporting?

Answered on November 30th 2023 by Attorney Gregory Dell
A: Jeanne:The beneficiary, which would be you, is responsible for a legitimate overpayment regardless of who ... Read More >
Helpful Videos
(888)
Showing 12 of 888 Videos
Disability Benefit Tips
(330)
Showing 8 of 330 Benefit Tips

Is UNUM a Good Insurance Company?

One common question the attorneys here at Dell Disability Lawyers receive comes from policyho... Read More >

How Long Does UNUM Long Term Disability Last?

When it comes to long term disability (LTD) insurance, every UNUM disability insurance policy... Read More >

Can You Sue UNUM?

If UNUM denies your long term disability insurance claim, can you sue? Generally, t... Read More >

How Does UNUM Define Disability?

UNUM Group - the Tennessee-based Fortune 500 insurance company that includes UNUM US, UN... Read More >

Beware of Traveling While on Disability with Unum

In the past several months our office has been hired by two separate clients who had individual disability policies purchased privately throug... Read More >

If I Sue Unum for a Disability Insurance Denial, What Should I Anticipate?

Disability insurance Attorneys Gregory Dell and Stephen Jessup discuss the numerous issues th... Read More >

Unum Disability Benefit Denial Trends, A Legal Perspective

In this video we discuss the recent trends they have observed with regard to Unum Insurance C... Read More >

A New Bait and Switch Tactic by Unum Disability Insurance Company

Unum reached a new low today which displays absolute disregard for the rights of a UNUM insured. Our law firm advised Unum in a January 16, 20... Read More >
Dell Disability Cases
(375)
Showing 8 of 375 Dell Disability Cases

Transportation Manager with Brain Injury Wins Unum Disability Benefit Appeal

Unum unjustly terminated our client’s long term disability claim after it had approved and... Read More >

Louisiana State College Director Wins Unum LTD Appeal But Then Denied Again

Client was Regional Director for the State of Louisiana. She was diagnosed with cervical rad... Read More >

Unum Approves LTD Benefits for Pharmacist with Eye Disorder

Rachel Alters of Dell Disability Attorney’s currently represents an Ambulatory Operations P... Read More >

Billing Manager With Back Disorder Wins Unum Long Term Disability Denial Appeal

Despite suffering with chronic knee and back pain for 7 Years, Unum still needed to be convi... Read More >

Unum Lifts Mental Health Limitation on Disability Claim

When our client first contacted our office and spoke with Attorney Stephen Jessup her claim for long term disability benefits had been approve... Read More >

Unum Approves Long Term Disability Application to a Program Manager

Our client, a high level Program Manager for a large international aeronautics company, was involved in an automobile accident that resulted i... Read More >

After appeal filed by Attorney Jay Symonds, UNUM overturned previous denial of long term disability benefits for South Carolina Nurse

Our client, Ms. L, formerly worked as a Registered Nurse for a nursing home. In November 2014 a number of chronic physical conditions and pain... Read More >

Unum Overturns Original Decision to Deny Benefits to Disabled Account Manager Following Appeal Submitted by Dell Disability Lawyers Appeals Team

In 2016, Sarah, an Account Manager, began suffering severe abdominal pain accompanied by bloody diarrhea. The frequency and condition was so s... Read More >
Disability Lawsuit Stories
(765)
Showing 8 of 765 Lawsuit Stories

Unum Wrongfully Terminated Disabled Lawyer’s Disability Claim of Depression and Anxiety Despite Improvement in His Condition

This Unum lawsuit and appeal in federal court is a great victory for all Unum disability claimants. This ca... Read More >

Court Rules Plaintiff's Medical Records Was Replete With Evidence Supporting Claim of MS & Was Not A Pre-Existing Condition

BackgroundIn Bayer v. Unum Life Insurance Company of America, C.A. No. 18-9702 (E.D. LA 2020), Plaintiff began working as a seni... Read More >

After paying for 13 years Unum Denies Disability Benefits to Woman with Lyme Disease and Endometriosis

In Stephanie Dorris v. Unum Life Insurance Company of America (Unum), Plaintiff was President of Beans Plus, Inc... Read More >

Inexperienced Lawyer Handles Unum Disability Lawsuit and Fails to Provide Evidence to Support Occupational Argument

The case of Stephanie Dorris v. Unum Life Insurance Company of America (Unum) is an example of how an inexperien... Read More >

Can UNUM Deny LTD Benefits When Plaintiff Proves Eligibility by a Preponderance of the Evidence?

In the case of Paul Luu v. First Unum Life Insurance Company of America (Unum), Plaintiff had been employed by MUFG Union Bank ... Read More >

Is Remand Required If Plaintiff Proves Disability by a Preponderance of the Evidence?

In Ralph Dewsnup v. Unum Life Insurance Company of America (Unum), Plaintiff was a trial attorney with the law firm of&nbs... Read More >

Can Unum Deny My LTD Benefits After Paying For 15 Years?

In the case of Michael J. Christoff v. Unum Life Insurance Company of America (Unum), plaintiff was a partner in the firm ... Read More >

Court Rules Proper Standard of Review is Abuse of Discretion

In Christoff v. Unum Life Insurance Company of America, Plaintiff Christoff suffered from severe fibromyalgia. He was insured under a group em... Read More >

Reviews from Our Clients

Request a Free Consultation

Our Lawyers Respond Same Day

5 Ways We Help Get Your Benefits Paid

Get Your Disability Application Approved

Our goal is to get your application for disability income benefits approved. Applying for disability benefits can be a difficult process and the information you provide is critical. Most disability insurance companies look at your application in hopes of finding a reason to deny your claim. Your disability company will ask you to complete numerous forms, interview you, request lots of information, speak with your doctors and possibly request to have you examined by their "hired gun" doctor.

Through our experience of having helped thousands of disability insurance claimants, our lawyers will guide you through the entire application process and give you the best chance to get your disability claim approved the first time.

Submit A Strong Appeal Package

If your disability insurance benefits have been wrongfully denied, then our lawyers know exactly what it takes to get your disability claim approved. You only get once chance to submit an Appeal, therefore every piece of evidence that will support your disability claim must be included. The goal is to win your disability benefits at the Appeal level, but while preparing your Appeal you must consider how a federal judge will review your disability claim if your benefit denial is upheld.

Preparing a strong disability appeal package is an art that requires you to understand how the courts interpret your disability policy language, ERISA regulations / laws, and how to strategically present evidence in support of your definition of "disability". We encourage you to contact any of our lawyers for a free immediate review of your disability denial.

Sue Your Disability Company

98% of the disability insurance lawsuits filed by our law firm have resulted in either the payment of benefits or a lump-sum settlement agreement. Our disability lawyers have filed ERISA governed and private policy long term disability insurance lawsuits against every major disability insurance company in state and federal courts nationwide and we love fighting for the "little guy" against the multi-billion dollar insurance company giants.

We have recovered hundreds of millions of dollars for our clients and we would like the opportunity to provide you with a free review of your disability benefit denial. There are many complex factors in a disability benefit lawsuit and the legal battle to win long term disability benefits can be fierce.

Prevent A Disability Benefit Denial

Approval of long-term disability is a continuous process as every disability insurance company will evaluate your eligibility for benefits on a monthly basis. You can never let your guard down and assume that your disability company will continue to pay your benefits for as long as you think you need them.

Our law firm offers a reasonable flat fee monthly claim handling service in which we handle every aspect of your long-term disability claim and do whatever it takes to make sure you are paid every month.

Negotiate a Lump-Sum Settlement

Let's discuss if a lump-sum settlement or buyout of your disability insurance claim is both available and makes financial sense for you. Our lawyers have negotiated more than five-hundred million dollars in disability insurance buyouts and we know how to get you a maximum settlement. A disability insurance company is not required to offer a buyout and not every disability company offers them.

Questions About Hiring Us

Who are Dell Disability Lawyers?

We are disability insurance lawyers that know how to get your short or long term disability benefits paid. As a nationwide law firm we have helped thousands of disability insurance claimants throughout the United States to collect hundreds of millions of dollars of disability insurance benefits from every major disability insurance company.

In more than 98% of our cases, our lawyers have been able to either get our clients paid monthly disability benefits or obtain a one-time lump-sum settlement. Our lawyers have seen it all when it comes to disability insurance claims and we know exactly what it takes for your disability claim to be approved.

We welcome you to contact any of our attorneys for a free immediate review of your disability claim. We also invite you to visit and subscribe to our YouTube channel where we have more than 700 videos and regularly provide tips to help protect your disability benefits.

Who do you help?

Our lawyers help individuals that have either purchased a long term disability insurance policy from an insurance company or obtained short or long term disability insurance coverage as a benefit from their employer. We have helped individuals in almost every type of occupation with monthly disability benefit payments ranging from $1,500 to $50,000.

Our clients include all types of employees ranging from retail associates, sales representatives, government employees, police officers, teachers, janitors, nurses, pilots, truck drivers, financial advisors, doctors, dentists, veterinarians, lawyers, consultants, IT professionals, engineers, professional athletes, business owners, and high level executives.

A strong understanding and presentation of the duties of your occupation is essential for securing disability insurance benefits.

Do you work in my state?

Yes. We are a national disability insurance law firm that is available to represent you regardless of where you live in the United States. We have partner lawyers in every state and we have filed lawsuits in most federal courts nationwide. Our disability lawyers represent disability claimants at all stages of a claim for disability insurance benefits. There is nothing that our lawyers have not seen in the disability insurance world.

What are your fees?

Since we represent disability insurance claimants at different stages of a disability insurance claim we offer a variety of different fee options. We understand that claimants living on disability insurance benefits have a limited source of income; therefore we always try to work with the claimant to make our attorney fees as affordable as possible.

The three available fee options are a contingency fee agreement (no attorney fee or cost unless we make a recovery), hourly fee or fixed flat rate.

In every case we provide each client with a written fee agreement detailing the terms and conditions. We always offer a free initial phone consultation and we appreciate the opportunity to work with you in obtaining payment of your disability insurance benefits.

Do I have to come to your office to work with your law firm?

No. For purposes of efficiency and to reduce expenses for our clients we have found that 99% of our clients prefer to communicate via phone, email, fax, GoToMeeting sessions, or Skype. If you prefer an initial in-person meeting please let us know. A disability company will never require you to come to their office and similarly we are set up so that we handle your entire claim without the need for you to come to our office.

How can I contact you?

When you call us during normal business hours you will immediately speak with a disability attorney. We can be reached at 800-698-9159 or by email. Lawyers and staff must return all client calls same day. Client emails are usually replied to within the same business day and seem to be the preferred and most efficient method of communication for most clients.