Re: Adams v. Poling
Dear Mr. Siegel:
A week back I received your letter and court papers telling me, in essence, that you would respond to my interrogatories and document requests to the extent that they were not objectionable for one reason or another provided I agree to keep your answers a deep dark secret.
You do not indicate which of the questions nor which of the documents you do intend to produce eventually. It would be greatly helpful if you could indicate what it is that you are talking about. Without such a statement, your Responses are really utterly useless formalities.
You also say that as of September 20, you were working on a motion for a protective order.
I think you know that in August, my wife and I were on a cruise up the Danube from Bucharest to Budapest. Sadly, she was in increasing discomfort as the trip progressed and immediately upon our return I took her to the doctor, where, within hours, she was found to have developed a pancreatic cancer. She is of the very lucky and very small minority of people with such a tumor where it is operable, and a week ago she underwent what seems to be successful surgery.
I mention this because my time is, for the foreseeable future, less my own than is usually the case. It would be very useful for me to know when to expect your motion so that I can plan my time around it.
Of course it may also be, given your client's participation last Friday in a very successful press conference concerning the very matters defendant here had the bad luck to write about, that you may wish to rethink your argument that your client is a quiet, private person who should not be subjected to having her name, face and affairs made public by journalism.
Sincerely yours,
Neal Johnston
NJ:ig
cc. James Poling
On another note, our thoughts are with Neal and his wife and we wish them all the best through this time in their lives.
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