Case: Velazquez v. Legal Services Corp

Dobbins v. Legal Services Corp

Velazquez v. Legal Services Corp,

Velazquez v. Legal Services Corp.

Velazquez v. Legal Services Corporation

U.S. Court of Appeals for the Second Circuit

Velazquez v. Legal Services Corporation

U.S. Court of Appeals for the Second Circuit

Legal Services Corporation v. Velazquez

Supreme Court of the United States

Legal Services Corporation v. Velazquez

Supreme Court of the United States

Legal Services Corporation v. Velazquez; United States v. Velazquez

Supreme Court of the United States

Velazquez v. Legal Services Corporation

Supreme Court of the United States

Velazquez v. Legal Services Corporation

Helen J. Knowles

Oyez

COMPLAINT filed and summons(es) issued for Legal Services Corp, Legal Services for FILING FEE $ 150.00 RECEIPT # 190973 (Chow, Alice) (Entered: 01/17/1997)

RETURN OF SERVICE executed as to Legal Services Corp, Legal Services for NY on 1/15/97. Answer due on 2/4/97 for Legal Services for NY , for Legal Services Corp. (Greves, Liz) (Entered: 01/23/1997)

Pltffs' Amended Disclosure of interested parties. (Greves, Liz) (Entered: 01/29/1997)

Pltffs' AMENDED COMPLAINT, (Answer due 2/6/97 for Legal Services for New York City, for Legal Services Corp. ) amending [1−1] complaint (Romano, Dan) (Entered: 01/30/1997)

AMENDED SUMMONS(ES) issued for Legal Services Corp, Legal Services for New York, Inc. (Romano, Dan) (Entered: 02/04/1997)

ORDER dated 1/29/97 that a status conference will be held at 4PM on 3/7/97 before Magistrate John L. Caden. (signed by Magistrate John L. Caden). (Greves, Liz) (Entered: 01/30/1997)

AFFIDAVIT OF SERVICE by Genevieve Lengard Re: [4−1] amended complaint, amended disclosure of interested parties upon Legal Services for New York City on 1/28/97. (Piper, Francine) (Entered: 03/12/1997)

NOTICE of attorney appearance for Legal Services Corp by Alan Levine. (Asreen, Wendy) (Entered: 02/21/1997)

Calendar entry: Before Judge Block on 2/19/97 case called; counsel for all sides present. Status conferenc held by phone. Preliminary injunction hearing set for 2:00 3/24/97 before Judge Frederic Block . All papers must be filed with the Court by 3/14/97. (Romano, Dan) (Entered: 03/17/1997)

STIPULATION of dismissal dated among plaintiffs and Legal Services for New York City. (Asreen, Wendy) (Entered: 02/21/1997)

LETTER dated 3/14/97 from Kaye, Scholer, Fireman, Hays &Handler to Alan Levine, Services of Class Certification and Preliminary Injunction. (Romano, Dan) (Entered: 03/18/1997)

USA's Notice of UNOPPOSED MOTION to intervene. (Greves, Liz) (Entered: 04/16/1997)

MEMORANDUM by USA in support of [24−1] motion to intervene. (Greves, Liz) (Entered: 04/16/1997)

ANSWER to Complaint by Legal Services Corp. (Greves, Liz) (Entered: 03/20/1997)

Pltffs' MOTION for class certification &a preliminary injunction. Motion hearing 3/24/97 at 10AM. (Greves, Liz) (Entered: 03/26/1997)

Declarations &Affidavits in support of pltffs' motion for class certification &preliminary injunction. (Declarations &Affidavits A thru M annexed). (Greves, Liz) (Entered: 03/26/1997)

Pltffs' Memo of Law in support of pltffs' motion for a preliminary injunction. (Greves, Liz) (Entered: 03/26/1997)

Pltffs' Supplemental Memo of Law in support of their motion for a preliminary injunction. (Greves, Liz) (Entered: 03/26/1997)

MEMORANDUM by Legal Services Corp in opposition to pltffs' [13−1] motion for class certification &a preliminary injunction. (Greves, Liz) (Entered: 03/26/1997)

Declarations in support of defts' opposition to pltffs' motion for a preliminary injunction. (Declaratins A &B &Exhbitis 2, 3, 4, &5 annexed). (Greves, Liz) (Entered: 03/26/1997)

Pltffs' REPLY MEMORANDUM OF LAW re: [13−1] motion for class certification &a preliminary injunction. (Greves, Liz) (Entered: 03/26/1997)

MEMORANDUM by Legal Services Corp in opposition to [13−1] motion for preliminary injunction. (Greves, Liz) (Entered: 03/26/1997)

ORDER, dated 3/26/97 granting pltff permission to file Reply Memorandum which is five pages longer than the Court's ten page limit. ( signed by Judge Frederic Block ). (Gonzalez, Mary) (Entered: 04/04/1997)

OPPOSITION of Intervenor−deft USA to pltffs' [13−1] motion for a preliminary injunction. (Greves, Liz) (Entered: 04/16/1997)

Calendar entry before Mag. Caden dated March 24, 1997. All counsel has advised the Mag. Judge nothing by way of discovery is presently contemplated if a Rule 16(b) conf is required, counsel will so advise the Mag. Judge. (Joseph, Derek) (Entered: 03/25/1997)

TRANSCRIPT of hearing before Judge Block filed for dates of 3/24/97. ESR Operator R. Eppenstein. (Greves, Liz) (Entered: 03/27/1997)

LETTER dated 3/31/97 from Alan Levine to Judge Block, submitting this letter to request that the Court consider the following in connection with pltffs' motion for a preliminary injunction. (Romano, Dan) (Entered: 04/22/1997)

LETTER dated 5/22/97 from Alan Levine to Judge Block, advising the Court that, since oral argument in this matter LSC has made material changes to its regulations concerning "interrelated organizations", and "program integrity". (Romano, Dan) (Entered: 06/17/1997)

LETTER dated 5/29/97 from Jeffrey Markowitz to Judge Block, responding to the letter sent to the Court by Alan Levine, on behalf of deft LSC regarding promulgated regulations. (Romano, Dan) (Entered: 06/18/1997)

LETTER dated 5/27/97 from E. Joshua Rosekranz to Judge Block, requesting that the Court should enjoin the restrictions on the use of non−LSC funds. (Romano, Dan) (Entered: 07/30/1997)

LETTER dated 9/22/97 from Peter M. Fishbein to Judge Block re: plaintiffs' motion for a preliminary injunction. Final new regulations have been approved and a proposed plan for creating an affiliate entity has been concretely rejected by LSC pursuant to 45:1610. (Guzzi, Roseann) (Entered: 11/13/1997)

MEMORANDUM AND ORDER denying plaintiffs' [13−1] motion for preliminary injunctive relief, as plaintiffs have failed to establish a probability of success on the merits of their facial constitutional challenge. Signed by Judge Frederic Block on 12/22/97. c/m (Asreen, Wendy) (Entered: 12/31/1997)

NOTICE OF APPEAL by Carmen Velazquez, WEP Workers Together, Community Service, New York City Co, Centro Independiente, Greater N.Y. Labor−, Farmworkers Legal, Lucy A. Billings, Peggy Earisman, Olive Karen Stamm, Jeanette Zelhof, Elisabeth Benjamin, Jill Ann Boskey, Lauren Shapiro, C. Virginia Fields, Guillermo Linares, Stanley Michels, Adam Clayton Powell IV, Lawrence Seabrook, Scott M. Stringer Fee Paid $ 105.00 Receipt # 202707 Notice of Appeal and certified copy of docket sent appealing [34−1] order. NOA served by the Clerk. Judge notified. C of A notified. (Gonzalez, Mary) (Entered: 01/13/1998)

Calendar entry: Before Judge Block−Case called, all counsel present and conference held. Discovery rulings made on the record. Plaintiffs appeal is pending in the Second Circuit. Galeano, Sonia (Entered: 01/22/1998)

LETTER dated 6/5/97 from Peter M. Fishbein to Judge Block that Jeffrey S. Markowitz' letter of 5/29/97 misses the point of plaintiffs' objections to LSC's latest version of its regulations in such a way as to illuminate the unconstitutionality of taking the Title X regulations approved in Rust and applying them willy nilly in the context of legal services. (Guzzi, Roseann) (Entered: 02/05/1998)

Document #30 and #31 were letters that did not belong to this case. Deleted. Those documents cannot be found at this time, if and when found they need to be docketed in the correct case which is case #95cv3403. (Guzzi, Roseann) (Entered: 02/05/1998)

ORDER dated 1/20/98 that defendant is ordered to provide plaintiffs with information regarding those applications for funding that have been submitted since issuance of its "final regulations" on 5/21/97, said information to include the name and address of all applicants, the date of the application, the nature of the application, the action taken by the defendant in respect thereto, and any stated reasons for the denial of any such applications. Defendant shall provide plaintiffs' counsel with access to such document for inspection and copying, at plaintiffs' own expense. All other discovery shall be stayed pending a decision from the Court of Appeals for the Second Circuit from this Court's denial of plaintiff's motin for a preliminary injunction. C/M ( signed by Judge Frederic Block ) (Guzzi, Roseann) (Entered: 02/06/1998)

(copy) LETTER dated 9/25/97 from Jeffrey Markowitz, Esq., to Judge Block, stating that nothing in the 9/22/97 letter of Peter M. Fishbein affects or alters the inquiry before the Court. (Asreen, Wendy) (Entered: 02/11/1998)

(copy) LETTER dated 9/26/97 from Alan Levine, attorney for Legal Service Corp., to Judge Block, stating that no plaintiff has attempted to comply with the program integrity regulations and therefore the court should deny their request for a preliminary injunction. (Asreen, Wendy) (Entered: 02/11/1998)

Certified and transmitted (INDEX) record on appeal to U.S. Court of Appeals: [35−1] appeal . Acknowledgment requested. (Gonzalez, Mary) (Entered: 02/12/1998)

Acknowledgment from USCA received re: [35−1] appeal. Acknowledgment signed by DMS on 2/17/98. (McGee, Maryann) (Entered: 02/20/1998)

LETTER dated 01.23.98 from Stephen L. Ascher to Judge Block requesting clarification of Your Honor's Order concerning discovery in this matter. Galeano, Sonia (Entered: 08/24/1998)

MANDATE OF USCA (certified copy) Re: [35−1] appeal. Ordered, Adjudged and Decreed that the Order of the District Court is Affirmed in part and reversed in part in accordance with the opinion of this Court. Issued as Mandate 8/25/99. Acknowledgment returned to USCA. Judge notified. USCA#98−6006. (McGee, Maryann) (Entered: 09/02/1999)

CASE NO LONGER REFERRED TO Magistrate John L. Caden (Chow, Alice) (Entered: 06/15/2000)

CASE REFERRED to Magistrate Viktor V. Pohorelsky (Chow, Alice) (Entered: 06/15/2000)

(FAX)LETTER dated 7/10/00 from Denise H. McNery to U.S. Court of Appeals requesting that the record be transmitted to the Supreme Court of the United States. Supreme Court #99−603 and #99−960. USCA#98−6006. Please note: although this letter is dated 7/10/00, it was not received by the District Court until 8/28/00 via fax from Fred Nunnery − USCA. (McGee, Maryann) (Entered: 08/29/2000)

Certified and transmitted record on appeal to Supreme Court for the United States − Office of the Clerk. The following documents were forwarded: 1−3, 5−10, 12,14,19,35,36,38,39,40. The remainder of the file is missing at this time. Record was requested by Denise McNerney (see document #44). It is being sent to her attention. Supreme Court docket #99−603 and 99−960. Acknowledgment requested. (McGee, Maryann) (Entered: 08/29/2000)

Record forwarded to Supreme Court of the United States via Federal Express. Federal Express Tracking #809824547710. (McGee, Maryann) (Entered: 08/29/2000)

Transmitted first supplemental record on appeal. The following documents were forwarded to the Supreme Court − Washington D.C #22, 24, 26, 25, 32, 33, 43 and 44. This package is being sent via Federal Express to the attention of Denise J. McNerney (Merits Cases). Tracking #814414125528 (McGee, Maryann) (Entered: 08/30/2000)

LETTER dated 6/6/01 from William R. Kirschner to Robert C. Heinemann, enclosing copies of the notice of appearance of William R. Kirschner. "Attachment" (Sica, Michele) (Entered: 06/20/2001)

NOTICE of attorney appearance for usa by William R. Kirschner (Sica, Michele) (Entered: 06/25/2001)

LETTER dated 5/8/0 from Burt Neuborne to Judge Block on behalf of plaitiff requesting a status conference. (Guzzi, Roseann) (Entered: 06/15/2001)

LETTER dated 5/18/01 from Alan Levine to Judge Block on behalf of Legal Services Corporation in response to plaintiff's request for status conference. (Guzzi, Roseann) (Entered: 06/15/2001)

LETTER dated 6/4/01 from Charles S. Sims to Michael J. Innelli, requesting the court advise whether or not Legal Services of New York need appear at the status conference set for 6/20/01. (Sica, Michele) (Entered: 06/21/2001)

LETTER dated 6/12/01 from David S. Udell to Judge Block, confirming the adjournment of the status conf. from 6/20/01 to 6/26/01 at 5:00. (DiLorenzo, Krista) (Entered: 06/26/2001)

Calendar entry: Before Judge Block − Status conf. held. All counsel present; counsel will submit briefs with respect to discovery and the standing issue of the parties. (DiLorenzo, Krista) (Entered: 06/27/2001)

LETTER dated 8/10/01 from Burt Neuborne to Alan and Will, written to ask if the Legal Services Corporation has given additional thought to the possibility, suggested by Alan at the recent status conference, that there may be some opportunity to settle this case. (Dobkin, David) (Entered: 08/14/2001)

LETTER dated 8/10/01 from Burt Neuborne to Alan Levine and Will Kirschner, inquiring whether the Legal Servicves Corp. has given additional thought to the possibility suggested at the recent status conference. (Dobkin, David) (Entered: 10/17/2001)

LETTER dated 10/11/01 from David Udell to Stephen Wieder and Will Kirschner, written to cnfirm that he is planning to serve plaintiffs' papers on 10/26/01. (Dobkin, David) (Entered: 10/17/2001)

LETTER dated 10/26/01 from David Udell to Stephen Wieder and Will Kirshner confirming that plaintiff's papers will be served on 11/9/01. (Rodriguez,Angela) (Entered: 10/31/2001)

LETTER dated 11/8/01 from David Udell to Stephen Wieder and Will Kirschner, confirming 11/16/01 as the proposed date for submission of plaintiffs' papers. (Dobkin, David) (Entered: 11/14/2001)

LETTER dated 11/16/01 from David Udell to Stephen Wieder and Will Kirschner, advising that plaintiffs' now plan to serve their papers on 11/20/01. (Dobkin, David) (Entered: 11/20/2001)

LETTER dated 11/30/01 from David Udell to Stephen Wieder and Will Kirschner, written to advise that plaintiffs now plan to serve their papers on 12/14/01. (Dobkin, David) (Entered: 12/06/2001)

MOTION by plt's for consolidation and a preliminary injunction . W/attached a−n. Forwarded to Chambers. (Noh, Kenneth) (Entered: 03/06/2002)

MEMORANDUM by plt's in support of [62−1] motion to consolidate Velazquez v. Legal Services Corporation and Dobbins v. Legal Services Corporation. Forwarded to Chambers. (Noh, Kenneth) (Entered: 03/06/2002)

MEMORANDUM of law in support of plt's [62−2] motion for a preliminary injunction. Forwarded to Chambers. (Noh, Kenneth) (Entered: 03/06/2002)

LETTER dated 12.14.1 from Burt Neuborne to USDJ Block re: status. (Noh, Kenneth) (Entered: 03/06/2002)

LETTER dated 1/7/02 from Stephen Wieder to Judge Block, stating that parties have agreed that responses to plaintiffs' motion for a preliminary injunction and to consolidate, and to the complaint in the Dobbins action, will be served by 1/22/02. (Dobkin, David) (Entered: 01/08/2002)

LETTER dated 2/5/02 from Stephen Wieder to Judge Block, advising the Court that the parties have agreed that responses to plaintiffs' motions for a preliminary injunction and to consolidate has been reset 4/12/02. (Dobkin, David) (Entered: 02/06/2002)

LETTER dated 4/10/02 from Stephen Ascher to Judge Block, advisng the Court that the parties have agreed that LSC's and U.Ss' responses to plaintiff's motoin for a preliminary injunction and to consolidate is adjourned to 5/3/02. (Dobkin, David) (Entered: 04/16/2002)

Acknowledge recipt of this APPEAL RECORD returned from Supreme Court of Washington, DC. Office, containing documents 2−14,19,22,23,23,26,32,35,35,38−44.( Copy of this letter of Acknowledgment sent back to Supreme Court of Washington DC.) (SCWDC#99−603,960) (Drayton, Lorraine) Modified on 04/25/2002 (Entered: 04/25/2002)

COPY of LETTER dated 5/3/02 from Stephen Ascher to David Udell, regarding enclosure of motion to dismiss papers. w/o enclosures. (Dobkin, David) (Entered: 05/08/2002)

LETTER dated 5/1/02 from Stephen Ascher to Judge Block, on behalf of deft LSC requesting permission to submit a memo of law of not more than 40 pages. (Dobkin, David) (Entered: 06/13/2002)

MOTION for amici curiae by Council on Foundations, Inc. Independent Sector, AARP Foundation, et al , Motion hearing [84−1] motion Motion file stamped: 6/19/02 (Dobkin, David) (Entered: 08/01/2002)

Brief in support of [84−1] motion for amici curiae by Council on Foundations, Inc. Independent Sector, AARP Foundation, et al (Dobkin, David) (Entered: 08/01/2002)

AFFIDAVIT of Stephen Ascher attorney for Legal Services Corp Re: certain documents before the COurt in opposition to plaintiffs' motion for a preliminary injunction and in support of LSC's motion to dismiss the complaint. Attached exhibits A−J. (Dobkin, David) (Entered: 07/24/2002)

MOTION by Legal Services Corp to dismiss , Motion hearing [73−1] motion Motion file stamped: 7/22/02 and mailed/served: 5/3/02. (Dobkin, David) (Entered: 07/24/2002)

Declaration of Laurie Tarantowicz in opposition to plaintiffs' motion for a preliminary injunction and in support of LSC's Re: [73−1] motion to dismiss (Dobkin, David) (Entered: 07/24/2002)

MOTION by Scott M. Stringer, Lawrence Seabrook, Adam Clayton Powell IV, Stanley Michels, Guillermo Linares, C. Virginia Fields, Lauren Shapiro, Jill Ann Boskey, Elisabeth Benjamin, Jeanette Zelhof, Olive Karen Stamm, Peggy Earisman, Lucy A. Billings, Farmworkers Legal, Greater N.Y. Labor−, Centro Independiente, New York City Co, Community Service, Carmen Velazquez, WEP Workers Together to consolidate cases and a preliminary injunction , Motion hearing [77−1] motion Motion file stamped: 7/22/02 and mailed/served: 12/17/01. Attached exhibit A−N and 1−36. (Dobkin, David) Modified on 07/24/2002 (Entered: 07/24/2002)

MEMORANDUM of law by Legal Services Corp in opposition to plaintiff's [77−1] motion to consolidate cases and a preliminary injunction, and in support of its [73−1] motion to dismiss. (Dobkin, David) (Entered: 07/24/2002)

REPLY MEMORANDUM OF LAW by Legal Services Corp in further support of its [73−1] motion to dismiss (Dobkin, David) (Entered: 07/24/2002)

MEMORANDUM of law by Scott M. Stringer, Lawrence Seabrook, Adam Clayton Powell IV, Stanley Michels, Guillermo Linares, C. Virginia Fields, Lauren Shapiro, Jill Ann Boskey, Elisabeth Benjamin, Jeanette Zelhof, Olive Karen Stamm, Peggy Earisman, Lucy A. Billings, Farmworkers Legal, Greater N.Y. Labor−, Centro Independiente, New York City Co, Community Service, Carmen Velazquez, WEP Workers Together in support of its [77−1] motion to consolidate cases and a preliminary injunction (Dobkin, David) (Entered: 07/24/2002)

MOTION by Scott M. Stringer, Lawrence Seabrook, Adam Clayton Powell IV, Stanley Michels, Guillermo Linares, C. Virginia Fields, Lauren Shapiro, Jill Ann Boskey, Elisabeth Benjamin, Jeanette Zelhof, Olive Karen Stamm, Peggy Earisman, Lucy A. Billings, Farmworkers Legal, Greater N.Y. Labor−, Centro Independiente, New York City Co, Community Service, Carmen Velazquez, WEP Workers Together to consolidate cases Velazquez V. Legal Services Corporation and Dobbins v. Legal Services Corporation , Motion hearing [83−1] motion Motion file stamped: 7/22/02 and mailed/served: 12/17/02 (Dobkin, David) (Entered: 07/24/2002)

LETTER dated 7/17/02 from Anne Nacinovich to David Udell re: enclosure of reply memo of law in support of legal services Corps motion to dismiss the complaint. w/o enclosure. (Dobkin, David) (Entered: 07/23/2002)

Declaration of Randi Youells in opposition to plaintiffs' motion for a preliminary injunction and in support of LSC's Re: [73−1] motion to dismiss (Dobkin, David) (Entered: 07/24/2002)

Declaration of Danilo A. Cardona in opposition to plaintiffs' motion for a preliminary injunction and in support of LSC's Re: [73−1] motion to dismiss (Dobkin, David) (Entered: 07/24/2002)

REPLY MEMORANDUM OF LAW by Scott M. Stringer, Lawrence Seabrook, Adam Clayton Powell IV, Stanley Michels, Guillermo Linares, C. Virginia Fields, Lauren Shapiro, Jill Ann Boskey, Elisabeth Benjamin, Jeanette Zelhof, Olive Karen Stamm, Peggy Earisman, Lucy A. Billings, Farmworkers Legal, Greater N.Y. Labor−, Centro Independiente, New York City Co, Community Service, Carmen Velazquez, WEP Workers Together in reply to the govt's opposition to motion for a preliminary injunction and in opposition to the govt's motion to dismiss. (Dobkin, David) (Entered: 07/24/2002)

ORDER granting [84−1] motion for amici curiae by Council on Foundations, Inc. Independent Sector, AARP Foundation, et al ( signed by Judge Frederic Block , on 6/19/02) (Dobkin, David) (Entered: 08/01/2002)

MOTION for leave of Nonprofit Coordinating Committee of New York, Inc. to appear amicus curiae , Motion hearing [89−1] motion Motion file stamped: 8/2/02 and mailed/served: 8/1/02 (Dobkin, David) (Entered: 08/08/2002)

LETTER dated 8/1/02 from David Udell to Judge Block, regarding the court of discovery disputes in the above case. (Dobkin, David) (Entered: 08/05/2002)

LETTER dated 8/6/02 from Stephen Ascher to Judge Block, requesting that the court hear oral argument on the jurisdictional issues before the currently scheduled discovery conference, and without receiving any additional briefing. (Dobkin, David) (Entered: 08/07/2002)

ORDER granting [89−1] motion for leave of Nonprofit Coordinating Committee of New York, Inc. to appear amicus curiae ( signed by Judge Frederic Block , ) (Dobkin, David) (Entered: 08/08/2002)

LETTER dated 8/9/02 from David Udell to Judge Block, stating that the Court not schedule oral argument until LSC has completed production of the documents plaintiffs seek, and until plaintiffs have had a chance to submit any relevant discovery materials to the Court. (Dobkin, David) (Entered: 08/12/2002)

LETTER dated 9/10/02 from David Udell to Judge Block, written to update the status of discovery. (original docketed under 97−cv−182 document # 92). (Dobkin, David) (Entered: 09/12/2002)

NOTICE of attorney appearance for usa by Richard G. Lepley (Dobkin, David) (Entered: 10/07/2002)

Calendar entry: Case called on 10/9/02 before Mag. Pohorelsky for initial scheduling. Counsel for parties. SCHEDULING AND RULING: 1. The next conference is adjourned sine die. Counsel shall advise the court of any date scheduled by Judge Block for oral argument or any other proceeding before him, and shall appear for a brief status conf immediately after the oral argument or other proceeding concludes; 2. The pltf's application to compel discovery is DENIED for the reasons set forth on the record. (Fernandez, Erica) (Entered: 10/11/2002)

LETTER dated 9/18/02 from David Udell to Mag. Pohorelsky,stating that plaintiff served their initial disclosures and await confirmation from defts regarding whether defts have any information appropriate for disclosure at this time. Plaintiffs continue to look forward to a rescheduled conference to resolve the problem of LSC's refusal to produce documents in discovery that are directly relevant to the cross motions pending before Judge Block. (Dobkin, David) (Entered: 10/10/2002)

LETTER dated 9/10/02 from David Udell to Mag. Pohorelsky, stating that the plaintiffs seek the Court's guidance regarding how to proceed to obtain the documents LSC has repeatedly promised but now refuses to produce. As set forth above, these documents are essential to the fair and accurate disposition of the motions pending before the district court. Attached exhibits 1−13. (Dobkin, David) (Entered: 10/10/2002)

LETTER dated 10/24/02 from Criag Siegel to Clerk of the Court, to submit the original and two copies of Plaintiffs' Objections to Order of Mag. Pohoreleky. w/enclosure. (Dobkin, David) (Entered: 10/29/2002)

LETTER dated 10/24/02 from David Udell to Judge Block, written to request oral argument on the parties; pending cross−motions and on plaintiuffs' request for further discovery; to enclose a new document produced by the LSC in discovery subsequent to the filing of the parties motion papers on 6/22/02; and to enclose a copy of plaintiffs' formal objections to the order of Mag. Pohorelsky entered on 10/9/02 denying further discovery. w/attachment. (Dobkin, David) (Entered: 10/29/2002)