ML20072N305

Forwards Response to Applicant First Set of Interrogatories & Request for Production of Documents & Apologizes for Late Filing.Related Correspondence

ML20072N305
Person / Time
Site:	Harris
Issue date:	03/29/1983
From:	Payne M EDELSTEIN & PAYNE, KUDZU ALLIANCE
To:	Baxter T SHAW, PITTMAN, POTTS & TROWBRIDGE
Shared Package
ML20072N309	List: ML20072N305 ML20072N324
References
NUDOCS 8304010501
Download: ML20072N305 (2)

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MTED CORRESPONDENCE EDELSTEIN AND PAYNE ATTORNEYS AT t.AW 723 WEST JOHNSON STREET POST OFFICE BOX 12643 ,

, RALEIGH. NORTH CAROLINA 27605 e82 IM 31 @

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s STEVEN R. EDELSTEIN (919) 828-1444 7, .S

u. T; Avis *AvNE March 29, 1983 (sisi ne-iany "[Y P.

.aw P tt Potts b , ..b.'. ((,, M - O h /

& Trowbridge * * " "

1800 M Street, N.W.

Washington, D.C. 20036 Re: Response to first set of interrogatories to joint intervenors Dear Tom; In response to your letter of March 23, 1983, I wanted to make clear that I was in no way attempting to avoid you or other counsel. for Applicancs , or cause you to unnecesscrily file a motion to compel. My schedule of hearings and preparation for an upcoming federcl trial has required me to be out of my office for much of the last 2-3 weeks. LTnen it became clear to me that I'would be unable to meet the March 10, 1983, deadline, I began trying to reach Samantha Flynn, local counsel for Applicants.

I was unsuccessful in reaching her, and as I was away from my office I could not leave a phone number where she could reach

me . Finally, after at least three calls, I left the message that I would have the responses prepared by Wednesday, March .23rd.

Upon receipt of your letter, I again tried to reach Ms. Flynn, with no success. ,

With regard to your call of March 15th, I did not return it because, quite literally, Kudzu Alliance does not have resources to be spent on unnecessary long distance phone calls. Unless it is absolutely necessary that you and I talk, I would prefer to conserve my client's resources by dealing with Ms. Flynn here in Raleigh.

I apologize for taking so long to get these responses filed.

At least part of the problem was the need to communicate and coordinate with the other joint intervenors, in order to prepare a single response for all four parties. I still think that a single joint response is beneficial to Applicants and Intervenors alike, bu't it obviously makes it more difficult and time-corisuming to pr'epare responses , particularly with intervenors in three different cities.

$$o?$@]

Thomas A. Baxter -

March 29,1983 Page 2 These responses were, in fact, drafted by last Wednesday, March 23, 1983. The additional delay was caused by the limited clerical resources of my office. My secretary was swamped with other work, including the necessity of preparing and filing a .

bankruptcy to prevent the foreclosure of one client's home. I felt that such matters had to take precedence over these interrog-atories.

I. am hopeful that in the future my schedule will be a lot less he,ctic than it has been over the past several weeks , and War there will nct be a sinilar breakdown in communicaticn between you and me. .

Sincerely ,

maiM. Travis Payre MTP/bn xc: All parties I

enclosure

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