I, JAMES ANDRUS, hereby declare:
1. I am over 18 years of age and a resident of the State of Wisconsin. I h ave personal knowledge of the matters set forth herein and, if called upon to do so, could and would competently testify thereto.
2. I am the owner of a chauffer service called Andrus Limousine Service, l ocated in Milwaukee, Wisconsin. In 1991, I employed Lawrence Wollersheim for about 6 months. In October of 1991, Wollersheim reported that he experienced pain in his lower back as a result of lifting while loading and unloading heavy luggage into and from a van on October 2, 1991. He reported that additional injury occurred as he continued to work lifting and carrying luggage on October 5, 1991. As he continued working, he claimed that the pain became disabling and he was unable to work any further.
3. While working for my firm, Wollersheim questioned another chauffeur who worked with him, Marc Stewart, about the availability of Workman's Compensation Insurance with our company. Marc stated to me at one point that he thought that Wollersheim was nuts.
4. Wollersheim subsequently filed a workman's compensation claim, for which he received significant payments from Workman's Compensation. This caused my own insurance premiums to shoot up significantly.
5. Based on my knowledge of the work done by Wollersheim and statements ma de to me by other chauffeurs who observed him while working, I can say without any hesitation that Wollersheim's claim was exaggerated and possibly a means of getting insurance money to handle a long standing physical problem which existed before he was employed by my firm. Wollershim discusses his previous back injuries in the attached letter of October 25, 1991. Wollersheim seemed to want all the work I could give him, and in retrospect I believe that he was planning all along to file a Workman's Compensation insurance claim.
6. Marc Stewart, who was on the job with Wollersheim when the injury allegedly occurred, indicated to me that he knew that Wollersheim's workman's compensation claim was questionable, and that Wollersheim was not lifting 10-15 suitcases as he claimed.
7. The health insurance claim form which Larry Wollersheim filled out gave a social security number of 398-096-167 and he spelled his name "Larry Wollershein" rather than the correct spelling of "Wollersheim". A copy of this form is attached.
I declare under the penalty of perjury under the laws of the United States of America, and under the laws of the State of Wisconsin, that the foregoing is true and correct.
Executed this 24 day of October, 1995 in Milwaukee, Wisconsin.