Document zoYBq73xaZJaKxkXoo9KEgpE0

ALBERT E. LEVY (1976 Ret.) WILLIAM V. MARCUS (197 Ret.) LARRY A. LEVY KENNETH W. LEVY S. ROBERT PRJNCIOTTORUSTINE TILTON DAVID L. RUTHERFORD cuffordB.singer- Member N J., D.C. A G*. Ban -Certified Civil Trial Attorney MARCUS & LEVY ATTORNEYS AT LAW December 3, 1987 Valley National Bank Bldg. 80 Broadway (Route 4) Elmwood Park, N.J. 07407 (201) 791-8500 Hon. Nicholas G. Mandak, A.J.S.C. Passaic County Court House Paterson, NJ 07505 REs Memice v. PPG Industries, Inc., et al Docket No. L-20509-87 Dear Judge Mandak: This matter is listed for a case management con ference on December 11, 1987. Please be advised that pursuant to the last case management order, I served interrogatories upon all De rendants that have made a motion for summary judgment. It is my rec Election that Your Honor indicated that the Defendants should answer said interrogatories as soon as possible and responsively a id the motions for summary judgment were carried until December 11, 1987. Please be advised that I have not received answers to said inter ogatories from any of the Defendants and therefore, I must enter my o 5 jection to the granting of these motions based upon the Defendants' f i ilure to provide this discovery. Pursuant to previous orders, five of the Defends * ts were to answer general sets of interrogatories. Those Defendan ts are PPG, Georgia-Pacific, Uniroyal and Ethyl Corporation and th *y have answered interrogatories. I have discussed more speci fic answers to these interrogatories with Claire T. Barile and have fb rwarded a letter to her confirming my request and she will advis which interrogatories will be answered voluntarily and which may require a judicial determination. The basis for more specific a iswers for almost all of the interrogatories is that no answer wa given. I have enclosed for Your Honor a copy of the set of Inte^: rogatories and at the present time requests have been made for answer to the following numbers: 3, 4, 5, 6, 7, 9, 10, 14, 12, 15, 16, 17, 18, 19, 20, 21, 22 24, 25, 26, 27, 28, 29, 30, 31, 32 33, 34, 35, 36, 37, 38, 39 41, 42, 43, 44, 47, 48, 49, 50, 52, 53, 54, 55, 56, 57, 58 59. I am hopeful that I will have a r|e sponse from Claire Barile as to which interrogatories will be answ ered without order and I would request that the balance be taken un|3 er consideration by Your Honor at the case management con ference on December 11, 1987. UCC 076614 ALBERT E. LEVY (1976 Ret.) WILLIAM V. MARCUS <1976 Ret.) LARRY A. LEVY KENNETH W. LEVY S. ROBERT PRINCIOTTO* RUST1NE TILTON DAVID L. RUTHERFORD CUFFORD B. SINGER- MemberN.J., D.C. AGe. Ban Certified Civil Trial Attorney MARCUS & LEVY ATTORNEYS AT LAW Valley National Bank Bldg. 80 Broadway (Route 4) Elmwood Park, N J. 07407 (201) 791*8300 Hon. Nicholas G. Mar dak, A.J.S.C. December 3, 1987 Page 2 With regard to expert reports/ I respectfully request tha t at the case management conference/ a time be set/ within vhich the Defendants shall supply medical expert reports and liability ex pert reports/ if any, and that a trial date be fixed. Finally, during the month of November, I had tel phone conversations with lead counsel, Claire T. Barile, rel< tive to the settlement of this matter and I made a demand for sett ement. She has indicated to me that there is some interest in set :ling this matter and she is awaiting responses from her respecti' e clients. In the event that Ms. Barile is of the opinion that a set lement conference would be productive, I would respectfully rt quest that the Court entertain a settlement conference on December 11 1987. Respectfully yours. SRP:amr Enclosure cc: All Counsel S. ROBERT PRINCIOTTO UCC 076615