BURTON A. SCHWALB
CHARLES R. DONNENFELD
JOHN M. BRAY
EARL J. SILBERT
JAMES K. STEWART
PHILIP D. GREEN
DAVID J. CURTIN
ALLEN V. FARBER
CHARLES B. WAYNE
STEVEN SARFATTI
LUCINDA J. BACH
PATRICIA L. MAHER
CARY M. FELDMAN
AMY 0. RUDNICK
KEITH R. ANDERSON
KEVIN M. DINAN
DOUGLAS C. MCALLISTER
DAVID N. YELLEN
ADELE P. KIMMEL *
JAMES A.BARKER, JR.
ERIC M. KATZ
STEPHEN P. MATTHEWS

*NOT ADMITTED IN D.C.

March 4, 1987

W. Edward Morgan, Esquire
Timothy Gresback, Esquire
Antioch School of Law
2633 16^th Street, N.W.
Washington, D.C. 20009
Re: Thomas v. The Washington Times, Inc.

Dear Mr. Gresback:

This will confirm that, upon receipt of your pleading styled as a "Motion to Stay the Mandate and Reargue the Case" in the above-captioned matter, I contacted you to request that it be withdrawn because it does not comply with the Rules of the District of Columbia Court of Appeals. You declined to do so. I further advised you that, based upon your refusal to withdraw your pleading and refile one which complies with the Appellate Rules, we have no choice but to oppose the Motion and to request that sanctions be imposed against you and/or your client.

/s/Lucinda J Bach

Lucinda Bach

LJB/ab

cc: Allen V. Farber. Esq.