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gators by CID on behalf of any defendant, for a period
of five years from December, 1980, in Oregon, Washing-
ton, Idaho, Utah and Montana.
* * * * * * *
c) That plaintiffs would perform investiga-
tions of suspected criminal and fraudulent activities
among defendants' insureds, employees, agents and
brokers in connection with CID's investigation and
attempted prosecution of insurance fraud; provide
equipment necessary thereto; and provide consulting
services, training and assistance necessary to enable
CID to establish and develop internal units with per-
sonnel capable of conducting such investigations on an
in-house basis.
* * * * * * *
4. From 1980-1984, plaintiffs performed investi-
gations described in paragraph VI-2(c) on behalf of
defendants.
* * * * * * *
6. * * * During 1980 to 1984, plaintiffs as-
sisted in training CID's regional (in-house) Criminal
Investigators. Plaintiffs built their own organization
capable of handling the defendants' investigation
needs. * * * Plaintiffs Peter and Shirley Diamond
devoted substantial time, effort and resources to their
performance of their agreement with defendants. * * *
7. In the summer of 1982, DCI started a business
called Evergreen Typing Service (hereinafter ETS) for
the purpose of providing transcription services to
defendants in connection with investigations. Owner-
ship of the business was later transferred to Peter and
Shirley Diamond. From time to time, plaintiffs in-
vested in new equipment for ETS and hired employees for
the purpose of dealing with CID's workload. From 1982
to 1984, ETS provided services to defendants.
8. Plaintiffs' actions in performance of their
agreement with defendants were done at the request of
defendants and with their knowledge, and were necessary
to the performance of plaintiffs' agreement with defen-
dants. Plaintiffs have performed all of their obliga-
tions under their agreement with defendants.
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