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8.A <br /> Page 59 <br /> PLG-Blake Lyon <br /> From: ATTY-Pamela Thompson <br /> Sent: Monday, November 15, 2010 2:28 PM <br /> To: 'Marc Warsowe'; Robert Carroll (RCarroll@matpelbuiiders.com) <br /> Cc: Phil Martin Qpm@kastnerkim.com); Ramirez, Veronica (VRamirez@bwslaw.com); PLG-Jill <br /> Ekas; PLG-Blake Lyon; HR-Bob Bell <br /> Subject: RE: St. Francis Appeal -- 11/22/10 <br /> Dear Mr. Warsowe: <br /> You asked that the hearing be continued. Just recently you mentioned that you had a conflict that called for your <br /> appearance elsewhere. The City Manager would like to take that into consideration, as f previously stated. You may <br /> support your request in any way that you see fit. I was merely pointing out to you that in evaluating the reasonableness ' <br /> of your request, some confirmation of the conflict in your schedule would be helpful. In the absence of such , <br /> confirmation, the hearing is set to go forward. ! <br /> As to the documents you may wish to ofFer, you have been asked to submit them as soon as possible. The clerk would <br /> prefer to have them today so that she can ensure your documents are distributed with the agenda packet. ' <br /> �a�rsePa. 7�io�rra&aoac <br /> Pamela Thompson <br /> City Attorney <br /> 1017 Middlefield Road <br /> Redwood City, CA 94063 <br /> Phone: (650) 780-7200 <br /> Fax: (650) 780-5963 <br /> From: Marc Warsowe [mailto:mwarsowe@sbcglobal.net] <br /> Sent: Friday, November 12, 2010 1:30 PM <br /> To: ATTY-Pamela Thompson <br /> Cc: Council-Jeff Ira; Council-Aficia Aguirre; Council-Ian Bain; Council-Rosanne Foust; Council-]eff Gee; Council-Barbara � <br /> Pierce; Council-John Seybert; MGR-Peter Ingram; PLG-Jill Ekas; PLG-Charles Jany; PLG-Christopher Rogers; CLK-Silvia <br /> Vonderlinden; Robert Carroll <br /> Subject: Re: St. Francis Appeal -- 11/22/10 <br /> Importance: High <br /> Dear Ms. Thompson, <br /> Thanlc you for your expression of concern about my assertion regarding the possibility of facing conflicting <br /> obligations on November 22nd. <br /> First, I hereby withdraw my request for a continuance for any reason other than a conflicting obligation due to <br /> my lawsuit in CT. If I am not in CT, I will be at the hearing, and hope and expect to have our Appeal resolved <br /> at that hearing, or as soon thereafter as is customary. <br /> We are renegotiating deposition schedules. This entails a lot of work and attorney costs. One would think that, <br /> as an attorney, you would understand what is involved in rescheduling multi-party depositions. Moreover, it is <br /> likely that I will be unable to inform you of the existence of a conflict before the 18th or 19th, or, possibly, only <br /> as of the day of the Appeal hearing. Is this acceptable? <br /> Since these are our depositions and they are being arranged without Court involvement by agreement of the <br /> parties, I am not aware that a subpoena or court order will be issued in the ordinary course of business, though I <br /> have not yet spoken with my CT attorneys about this specifically. But your demand for such stringent evidence <br /> i <br />