On 05/11/12, Defendant Newton refused Plaintiff WMSCOG’s Settlement Offer extended on 05/04/12.
You may read it in PDF or text format below.
- The Complaint 12/06/11
- Newton Demurrer 01/06/12
- WMSCOG Opposition to Newton Demurrer 01/12/12
- Court Order on Newton Demurrer 03/13/12
- Colón Motion to Dismiss 01/30/12, 02/10/12
- WMSCOG Opposition to Colón Motion to Dismiss 02/27/12
- Colón Reply to WMSCOG Opposition to Colón Motion to Dismiss 03/02/12
- Court Order on Colón Motion to Dismiss 03/16/12
- Newton First Set of Interrogatories 04/02/12
- Newton First Set of Requests for Production of Documents 04/02/12
- Newton Answer to Complaint 04/03/12
- WMSCOG First Set of Interrogatories 04/16/12
- WMSCOG First Set of Requests for Production of Documents 04/16/12
- WMSCOG Settlement Request 05/02/12
- WMSCOG Settlement Offer 05/04/12
- Newton Response to WMSCOG Settlement Offer 05/11/12
- WMSCOG Motion for Protective Order 05/18/12
- WMSCOG Memo in Support of Motion for Protective Order 06/11/12
- Newton Opposition to WMSCOG Motion for Protective Order 06/20/12
- WMSCOG Reply to Newton Opposition to Protective Order 06/27/12
- Court Order and Opinion on WMSCOG Protective Order 07/20/12
- WMSCOG Attorney John Dozier's Death 08/06/12
- WMSCOG Motion for Nonsuit 08/07/12
- Newton Motion for Sanctions 08/07/12
- WMSCOG Opposition to Newton Motion for Sanctions 08/17/12
- WMSCOG Motion for Withdraw As Council 08/31/12
- Court Order Final 09/17/12
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May 11, 2012
By Email [e-mail address]
John W. Dozier, Jr., Esq.
Dozier Internet Law, P.C.
11520 Nuckols Road, Suite 101
Glen Allen, VA 23059
Re: World Mission Soc’y Church of God v. Newton, Case N0. 2011-17163
I received your letter dated May 4, 2012, in which WMS offered to drop its baseless lawsuit in exchange for Mr. Newton and Ms. Colon agreeing to remove from the Internet “all references” to WMS and agreeing not to tell anyone about the arrangement. Mr. Newton and Ms. Colon reject your elient’s offer and are both looking forward to having their day in court.
As you know, Mr. Newton has granted WMS multiple discovery extensions to permit a sufficient opportunity to explore possible settlement and to discuss the possibility of entering into a protective order. At this point, Mr. Newton feels he has waited long enough. As I discussed with Mr. Szego, Mr. Newton will allow WMS until May 16, 2012, to answer the pending Interrogatories and Requests for Production of Documents. I do not expect him to agree to further extensions, so I look forward to receiving your client’s responses on or before that date.
Very truly yours,
Lee E. Berlik
cc: Tyler Newton
1250 CONNECTICUT AVENUE. NW • SUITE 200 • WASHINGTON DC 20086 • 202.449.8555