ML20126L539

Informs That If Applicant Answers to Committee to Bridge the Gap 810420 Interrogatories Are Not Received by 810526,client Will Consider Action to Be Breach of ASLB Order & Stipulated Agreement.Related Correspondence

ML20126L539
Person / Time
Site:	05000142
Issue date:	05/23/1981
From:	Pollock M COMMITTEE TO BRIDGE THE GAP, POLLOCK, M.
To:	Cormier W CALIFORNIA, UNIV. OF, LOS ANGELES, CA
References
NUDOCS 8106040445
Download: ML20126L539 (2)

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?2: FAILURE TC SER7E A??*.ICA: T'S A!.'3iiE?S TC I'CERVE :CR'S I'CERECCATCRI53 CF APRIL 20. 1981 Eear Mr. Cornier:

3y stipulated ageement among the parties, and by Crier of the 2 card, answers to the first set of intenegatories were to be served by Fay 20, 1961.

It is ny understanding that as of 7.ay 22, 391, Applicant's answers to Intervencr's intenegatories had not yet been served.

Cn "av 19,1931, you called my office requesting an extensicn of two days for the University to answer my client's intenegatories. After censultation with my client, our approval was granted en condition that the interrogatcries te hand-delivered to my client en "ay 22. Icu arreed, stating that the irterrogatory answers would be hand-<ielivered to y client's representatives during docunent inspection Friday aften cen.

I am inferred that at 5:00 p.m. , at close of document inspection Friday, Iariel Mi-sch, representative of ny client. Connittee to 3 ridge the Cap, was inforned that no interregatcry answers uculd te fortheening at that time.

Mr. "eill Cstrander, stating that he was passing en ucri frer you, said he did not kncu when the arsuers uculd be forthcoming, but thought "perhaps Iuesda:'."

3heuld my client not be in receitt of Acclicant's answers by 5:00 p. m.

Tuesday, 7ay 26. :/ client will have to censider this failure a breach of the 3eari's Crier and the stipulated agreenent regarding the discovery schedule, and will have to sericusly consider requesting 3 card assistance in ob.aining Applicant's compliance. As Applicant's failure to comply places a geat burden on Intervenor, due to the nearness of the June 10 deadline for felicu-up irter ogatories, and as Applicant has failed to ec= ply with previous 3 card Criers regarding discovery, Intervener ray feel cen;elled to request sancticns.

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.Mr. '.*1111am Cornier, Isq.

Fay 23,1981 Should Applicant be unable to deliver to Intervenor by c1cse of business Tuesday, Fay 26, said Answers, but have instead a proposal it requests Intervenor to consider regariing said Answers, that proposal should be likewise rade by 3: 00 p. m. Fay 26. As I will be in trial all day, contact shculd be rade directly .with Fr. Ianiel Rirsch of the Conmittee to 3 ridge the Cap, 1637 3utler, #203, I.os Angeles, CA cCO25, (213) 479-0629.

Applicant should be on notice that if it wishes to request of Intervenor censideration of time extension in any future c.atter, such request should be

~ade at least several days before the deadline in question.

Sincerely, -

N' Park ?c11cek Atter: cy for Intervencr CCFir"ZE TC 33IOCE TE CA?

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