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To: peter michaels who wrote (386)	12/22/1998 6:51:00 PM
From: Quahog	Respond to of 688

Where I live, one has to file a Motion to Default, then have a hearing before anyone is adjudged to be in "default," which is a term of art. I believe the fancy legal term you are looking for to describe being a day late is...."one day late."

To: peter michaels who wrote (386)	12/22/1998 8:45:00 PM
From: Virgo	Read Replies (1) \| Respond to of 688

Re: Peter's Posting #386- Email From John Zarian Jean, Set forth below is the text of a letter I just sent Peter's attorney: This will confirm our telephone conversation this morning, during which I advised you that I intend to file pleadings tomorrow {including a motion to strike} in response to your clients' frivolous "cross-complaint" in this matter, unless the Court grants us additional time in which to file. The response will be filed on behalf of Mr. Pulcrano and Ms. Boyer only, inasmuch as no other cross-defendants have been served. As you will recall, I wrote to you on December 1, 1998. At that time, I confirmed that your cross-complaint was delivered to my office on November 24, 1998, and I advised you that we would be filing a response to the cross-complaint on or before December 23,1998. We received neither a response nor any objection from you. Under the circumstances, I am shocked by your statement this morning that you intend to seek a default at 9 a.m. tomorrow if no response is filed today. Please rest assured that we intend to seek all available sanctions against you and your clients in the event you decide to seek the entry of an improper "default judgment" tomorrow morning. In addition, we hereby reserve all of our rights and all of our clients' rights to seek administrative or other appropriate relief in connection with your unprofessional conduct.