Third Generation Detectives Investigation Services1111 N. Main Street, No. 105 Santa Ana, California 92701
May 16, 1993
CONFIDENTIAL
Michael T. Stoller BESBRIS, HOLLIS & STOLLER Murdock Plaza 10900 Wilshire Blvd., Suite 1010 Los Angeles, California 90024
Re: BOWLES & MOXON vs. TED J. HEISIG, JR. Case No. BC 071626
Dear Mr. Stoller:
I am writing in response to your letter dated May 12, 1993.
Thank you for informing me of the fact that I have been legally served concerning the above entitled Los Angeles Superior Court action.
I am requesting that your office advise the court that "settlement"
negotiations have been initiated to resolve this matter in the form of mediation. Therefore, I expect my response date to be extended to July 1, 1993, instead of June 1, 1993. A conformed copy of your motion to the court should be mailed to my business address after it has been filed with the clerk's office. The granting of this extension of time will demonstrate your clients willingness to comply, and will be appreciated.
As to my "allegations" against Mr. Di Mauro, Bowles & Moxon and Eugene Ingram, I can tell you that I filed a three page complaint with supporting evidence to the State Bar of California on September 2, 1992. A copy of my complaint was also mailed to the Bureau of Investigative Services in Sacramento. I must point out, however, that subsequent to the filing of my complaint, I have received additional information which is pending further investigation.
In your last letter, you indicated that your client has expressed an interest in learning the "substance" of my allegations regarding Mr.
Di Mauro and Bowles & Moxon. Deposing me is no part of my proposal. As I am assuming Mr. Ingram and Mr. Di Mauro would not agree to relinquish their telephone records of calls to certain parties residing in the Orange and Riverside counties during the months of May, June, July and August of 1992.
Please understand that I am desirous of handling this lawsuit without the use of a public courtroom. I again want to reiterate that I am more than willing to sign a stipulation not to divulge any information that is considered confidential with respect to Scientology.
Have your client think about my proposal. I am confident that this offer will be mutually beneficial to all interested parties. I await your response within the next seven days.
Very truly yours,
[Signature]
THIRD GENERATION DETECTIVES Ted J. Heisig, jr.
cc: file
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