Document V7GZMpNB5evz2e1X6DBaaaEp

January 16, 1987 Hon. Nicholas G. Mandak Assignment Judge Superior Court of New Jersey Passaic County Court House Paterson, New Jersey 07505 Re; Mexnice v. PPG Industries, et al. Docket do. L-2050S-86 Dear Judcre Mandak: I am in receipt of a copy of Mr. Princiotto's letter to Your Honor dared January 13, 1937 by which he submits an alternate proposed form of Order in connection with the applications heard before Your Honor on December 19, 1926. Objection is hereby made, on behalf or all clienc.i represented by this office, to the entry of the Order submitted by Mr. Princiotto. As is set forth in Hr. Ridley's proposed form of Order, submitted to Your Honor under cover of his letter of January 8, 1987, and as Your Honor will recall, defendants sought and received from Your Honor the right to appear on short notice to object to the ten simple interrogatories to be served by plaintiffs, should that be necessary. Apparently, it is necessary. Mr Princiotto, however, is seeking to have Your Honor direct that the interrogatories which he has served be answered, despite his notice of substantial abjection on the part of the defendants. As did Mr. Ridley, I corresponded with plaintiff's counsel upon receipt of the new set of ten interrogatories, objected to Hon. Nicholas G. Manfiak January 16, 1987 Page 2. those interrogatories, and asked him to communicate with me to attempt to resolve our differences without the necessity of court intervention. On January 14, 1987 Mr. Princiotto and I conferred by telephone. We reviewed and discussed each and every one of the interrogatories served by him on January 5, 1987. I advised him that I believed only auestions 5, 6 and 9 were appropriate pursuant to Your Honor's directives, which were that these interrogatories be directed to each defendant's involvement, if any, with the supply of the subject product, VCM, to Pantasote, the decedent's employer in this matter. Mr. Princiotto, however, would nor. agree to accept answers to questions 5, 6 and 9 only, and advised me that he had submitted the interrogatories to Your Honor with the request that an Order be entered directing thar all ten mterrogatones be answered by all defendants. I reso'.ictfuily recuesc thar Your Honor deny this request, and provide the defendants with the opportunity to argue this matter be Lore Your Honor, should that be necessary. I note that Mr. Princiotto has sucgesced a telephone conference call with Your Honor ami :Tr. Hadley only. Since all defendants will be affected by any ruling o:i this .subject, I respectfully request that we have the right to participate in any conference or argument. Pesoectfully yours. CTB/mm cc: Claire T. Ba.nle For TOMPKINS, McGUI?2 & WACHEHFELD S. Robert Princiotto, Esq. All Defense Counsel bcc: All Clients