CONTACTS 
0201 - Wolkin & Timpane                   415 982 9390 fax 4328
020101 - Mr. Michael J. Timpane, Esq.

SUBJECTS
Pier 11 Fender project

0403 -    ..
0404 - Summary/Objective
0405 -
040501 - Follow up ref SDS 29 0000, ref SDS 18 0000.
040502 -
040503 - Received ref DRT 1 dated 990301 from Michale Timpane, representing UP
040504 - on the Pier 11 project.
040505 -
040506 - Mike cites his letter on 981114, ref DRP 8 received in the record on
040507 - 981118. ref SDS 29 6960, and requesting a proposal for payment of the
040508 - Welch obligation to UP in the amount of $527,154.88, as of 970206...
040509 - ref DRP 8 4883
040510 -
040511 - Mike explains an understanding from my call on 981123 that I was
040512 - sending a letter.  He says that since I did not send a letter, then if
040513 - I do not respond to his current letter, ref DRT 1 0001, by 990308,
040514 - then his client will proceed in a more formal fashion.
040515 -
040516 - Mike's understanding may be correct.  I called on 990303 to get his
040517 - email address in order to send a letter using our new "paperless"
040518 - management system. ref SDS 29 0816
040519 -
040520 - He did not call back, so I did not follow up, but this was clearly a
040521 - burden on me, so I erred.
040522 - ..
040523 - I called Michael's office.
040524 -
040525 - He was not in, so I left another voice mail.
040526 -
040527 - I apologized for failing to follow up correctly.
040528 -
040529 - I explained I would like his email address so I can submit a response
040530 - as he requests.
040531 -
040532 - I advised that I am unable to pay the obligation owed to UP, and I
040533 - asked him let me know what I can do to assist him is accomplishing
040534 - UP's decison in this matter.
040535 -
040536 - I made a general reference of progress with Communciation Metrics, but
040537 - acknowledged Mike's representation in his letter on 981114 that UP is
040538 - demanding payment, and does not want information on progress under
040539 - Mike's characterization about the "day of reckoning" having arrived.
040540 - ref SDS 29 5544
040541 -
040542 -    [On 990308 got Mike's email address, sent letter. ref SDS 31 3312]
040543 -
040544 -
040545 -
040546 -
040547 -
040548 -
040549 -
040550 -
040551 -
0406 -