Insurance High School

PETER PARROTT

Paralegal – Collections, Litigation, and Contracts

(Two positions, covering 15 years)

**** ******* *****

Harbor City, California 90710

Email: **********@*****.***

Phone: 310-***-****

OBJECTIVE:

I am a seasoned paralegal, with collections, and plaintiff-side litigation experience. I seek a new

position within 25 miles of my home in Harbor City, where I can put my successful experience in

collections and contracts to good use. I would prefer to work directly for a business, if possible.

My primary experience has involved ERISA claims collection and litigation of denied claims from

ERISA Health Plans, bringing in revenue for a Beverly Hills surgical center from denied claims. Every

ERISA Plan is a carefully designed and regulated contract. I am profoundly aware that I am a paralegal,

NOT a licensed attorney. If litigation over a dispute claim is necessary, I would like to work under the

direction of experienced and skilled attorneys, as part of a team. I believe I can make a significant

positive impact for any new employer.

Treasurer: Saint Lawrence Martyr School Parent Board (SLM) (Redondo Beach) (2013-2014)

I volunteered to serve as Treasurer for the fund-raising arm for my daughter’s school for her final year. I

supported the SLM fund-raising effort, which yielded about $200,000, for the 2013-14 school year.

Claims Paralegal for: Solutions Surgical Center (SSC) (1999-2012)(Beverly Hills)

In this collections and litigation position, my employer had a major problem: the ambulatory surgery

center (ASC) he owned was NOT GETTING PAID appropriately by insurance plans for high quality

medical care that the center had provided. Solutions Surgical Center (SSC), a “Joint Commission”-

accredited Ambulatory Surgical Center. SSC was a very significant business: we had two high tech,

fully equipped operating rooms, both in use every day. We were not being paid appropriately, but

Department of Labor (DOL) regulations seemed to favor us. I proposed and executed a legal solution

to the problem that succeeded so well and paid so well, I stayed in this Paralegal position for 15

years, until the owner (Dr. Reich) became too sick to work, in 2012.

We averaged 30 cash cases and 20 insurance cases per month. Because we were located in the City of

Beverly Hills, however, and because so many plastic surgeons used our surgical facility, reimbursement

1

on entirely valid insurance claims was difficult, and required vigorous effort, and often paid with sharply

discounted amounts. We had $150,000 to $200,000 per month in claim denials.

My Solution to the Denied Claims: DISCLOSURE REQUIRED UNDER FEDERAL LAW

When I analyzed the pile of denied insurance claims at SSC, I noticed that the insurance companies were

often issuing “summary” denials of our claims, as not medically necessary. The insurance companies

gave zero credit to the “medical necessity” documents that we provided, and refused to provide ANY of

the specific internal governing documents supporting their decisions to deny benefits for our claims.

That situation had to change substantially, if the financial health of SSC was to improve.

I proposed to Dr. Reich, the owner of Solutions Surgical Center that we pick a proper case, and sue a

Plan for disclosure in federal court under ERISA, the huge federal statute that controls all private health

plans and claims. The core of my strategy was based on 29 U.S.C. §1024(b)(4), a significant element of

the ERISA civil disclosure scheme. This section requires ERISA Plan Administrators to disclose “other

instruments” under which a claim had been denied. My theory was simple: if a sitting federal judge

would enforce the ERISA disclosure regulations on behalf of a physician, we would have a much greater

chance of getting our claims paid, in the future. My proposal that Dr. Reich sue in federal court for

disclosure and penalties under ERISA was radical, because no physician had ever done this sort of thing

before, and no attorney would take our case without a deposit of at least $25,000. We knew that there

would be a major challenge to: (1) Dr. Reich’s derivative standing to sue in Federal Court, and (2) a full

argument about the significance of the Department of Labor (CFR) Regulations governing disclosure

under ERISA. The proposal was also highly innovative, because we did not seek immediately seek

benefits (i.e. money): we sought disclosure and penalties only, for legal strategy reasons.

Dr. Reich and I won a Rule 56 summary judgment and were awarded disclosure penalties against

Universal Studios, on May 17, 1999. We prevailed in this matter without counsel. Dr. Reich appeared

Pro Se, based on derivative standing as an assignee. The case is on the federal PACER records system,

as Reich vs. Universal Studios, 99-cv-01254-AHM. This victory improved profitability immensely!

Prior Experience: Merrill Lynch, Pierce Fenner and Smith, other securities positions.

Education: Bachelor of Science degree, St. Mary’s College of California, Moraga CA.

Personal: Married for 15 years. My wife Lane Parrott and I are raising our 14-year-old daughter, who

is a freshman at Bishop Montgomery High School in Torrance.

2

3

Contact this candidate