United States District Court for the Eastern District of Pennsylvania

World Service Office, Inc. vs David Moorhead

Civil Action No. 90-7631

Philadelphia, Pennsylvania
April 29, 1992
Before the Honorable Louis H. Pollak, S.J.

Appearances:
For the Plaintiff:
John T. Synnestvedt, Esquire
Scott Fields, Esquire
2600 One Reading Center
Philadelphia, Pennsylvania 19107

For the Defendant:
Greg B. Emmons, Esquire
One Aldie Mansion
85 Old Dublin Pike
Doylestown, Pennsylvania 18901

From: Greg P. Emmons and Associates P.C.
One Settlers Drive
P.O.Box 926
Doylestown, PA 18901

To: Scott J. Fields, Esquire
Synnestvedt & Lechner
2600 One Reading Center
1101 Market Street
Philadelphia, PA 19107

July 22, 1992

Re: World Service Office, Inc v. David Moorhead
S & L File No. 17047

Dear Scott,

I have been advised that my client David Moorhead has died on July 14,
1992. Since his death, I have been contacted by several concerned
Fellowship Members who are willing to step forward as a substituted party
defendant to proceed on David's behalf under Federal Rule 25. The
necessity of continuing this action would be for the Court to monitor the
WSO compliance with the January 1991 Settlement Order and the April, 1992
Motion to Commit the Intellectual Property Trust Document as done under the
Court's supervision.

Over the last weekend, I met with several members of the Fellowship and
had the opportunity to hear at great length the dissatisfaction with the
manner in which the World Service Office has proceeded with compliance
under the Motion committing the Fellowship Intellectual Property Trust.
The Motion quite specifically requires that the World Service Board and a
RSR-Working Group "solicit" additional input on the Fellowship Intellectual
Property Trust for presentation to the Fellowship in the 1993 Conference
Agenda Report. There has been no know effort made to schedule any
workshops, there has been no know mailings submitted to the RSR's
respecting the manner and procedure that the home groups can submit review
and input for the Trust Document nor has the NA Way or World mailings even
mentioned solicitation of input. George Hollahan in his letter to me of
June 3, 1992, sets forth a deadline for input of October 1, 1992, however,
provides no instruction on how input can be submitted and to whom. I am
concerned that your client is not acting in good faith. Please have your
client advise as to what steps are being taken to solicit input and how
input can be received.

Further, in George Hollahan's letter dated June 3, 1992. Mr. Hollahan
provided me with copies of draft "Minutes" of several pages of day Four of
the WSC and also several pages of day Five of the 1992 WSC. I also
received a cassette tape of the proceedings that took place at the
conference on Wednesday morning, April 29, 1992. I was literally shocked
by the representation made by your clients that their legal counsel had
instructed them that the Moorhead legal action had no affect whatsoever on
their ability to go forward with the submission and approval by the
Ccnference of the World Service Board of Trustees Motion No. 8, "The
Fellowship Intellectual Property Trust". I do not understand whether this
claim by your clients is indicative of the lack of communication between
legal counsel and the WSO, a simply blatant disregard for the authority of
the Court while a legal action in the nature of a Motion for Preliminary
Injunction was pending. This concern is compounded when one considers the
strong feelings Judge Pollak expressed initially and were again clearly
evident during the Court conference call session held the morning of the
vote on the Motion to approve the Intellectual Trust Document. (I enclose
a copy of the transcript).

Finally, last week I received an Order entered by Judge Pollak in a
drafted form setting forth that my client's Motion for Expedited Proceeding
be denied. Was this Order generated by your request without advance notice
to me or was it Court generated? In any event, Judge Pollak correctly
modified the Order to add the words "as moot" to the denial of the
Preliminary Injunction and Expedited because of the result of the
conference vote on Wednesday, April 29, 1992. I would be suspect that the
Court will entertain a conference call to be made aware of the progress of
your client receiving input and the documented disregard for the authority
of the Court under the continuing jurisdiction. Please advise as to your
availability.

Very truly yours,
Greg B. Emmons
Greg B. Emmons and Associates, PC