Document kDD3ozDNBBQZ0Z1boemEEByay
FROM; mOSUIREWOORHISWELLS
FAX NO.: 407 423 3796
CaREC DIAL (407) 2*44-1 IBS OiPCCT **CS<UtwE (407)048-4664
IK"ERNET E-mail
Maguire, Voorhis Sc Wells, P.A
AC ?Cyv-< WNCE DL\2A 2 SO-.T-I DP4NGE AVENL5 ORLANDO. FLORIDA 32801 TELEPHONE (4C 7) 244-1100 cAC?imilE (407) 423-8796
PO 90x533 CRLANOO. *.D OA 32602
Chris n. Kolos
April 14, 1997
Sent Via Facsimile
David M. Lipman, Esquire 5901 S.W, 74th Street Suite 304 Miami, Florida 33143
Re: Tinker v. Mack Trucks, Inc., et a!. Ontario County Index No.: 83778
Dear David:
As a follow-up to my letters of April 3 and April 9, 1997, Mack reports to me that they have found documents responsive to paragraphs 7 and 1 1 of the Request to Produce and that they are willing to produce all that they find and not just exemplar copies. Thus, I believe this matter, which is the final one on my list, has been resolved. Mack has committed to produce the documents to me within one week. By then, I will also have the verification to the Supplemental Response to the First Set of Interrogatories served April 9th.
Based on my conversations with David Pollack, I believe this resolves all the outstanding issues with Mack. My intent here is to obviate my need to travel to Rochester for the hearing. Please advise if there is any reason why the Motion to Compel as to Mack is not resolved. The only issue remaining in David Pollack's mind was Mack's answers concerning its lack of knowledge of the percentage content of asbestos in its products. I told David that Mack already answered that it does not have that information. Pollack said he wanted to confer with you about this. All I can tell you David is that Mack stands by that answer.
Thank you for your attention to this matter.
CNK/mdh
OR!. ANDO
MEIS< H'RNE
TAl.I.AIiAS'iEF
FPOfl : PIQGUlSEUOOSrtlSiuELLS
FAX NO . : 40" 423 3 ? 9 6
David M. Lipman, Esq. April 14, 1997 Page 2
cc: Tom Wilcox, Esq. Tom VanStrydonck, Esq.
Michael Pontierio, Esq. David H. Pollack, Esq.
04- l 4-9? 0 3 2 0 2P P . 03
ORLANDO
ME! ROVKNE
I'ALLAJ IASSEE