Dear Ms. Fairweather:
I received your 12/16/99 letter today via Federal Express and I noted with some surprise that you refrained from sending it to me via FAX, as you had chosen to do when remitting a copy thereof to Judge Herron (in addition to sending it to him via the mails). Therefore, I am immediately responding; I am sending a copy of this letter to both of you via both avenues to ensure prompt receipt thereof. I called his chambers (215-686-9536) and acquired his FAX number (215-686-7049). Know that all documents will have been transmitted electronically by noon, today. If there is any problem with this plan, please so notify me; use either the above number or my cellular number (215-313-3869).
Allow me, please, to clarify my legal posture. Notwithstanding your assertion, a copy of my Motion for Reargument/Reconsideration was sent to Ms. McLaughlin on 11/22/99. Nevertheless, another has been appended hereto (freshly reprinted from my computer).
Your assumption that I have abandoned this Motion is in-error; the purpose for the filing to Commonwealth Court was to ensure that opportunity was not going to be lost because of the absence of a response from the Philadelphia Court of Common Pleas; it is my understanding that I could not assume the pendancy of the latter would toll the former.
Thus, I view the situation as before both courts. Incidentally,
on the day I hand-delivered the Notice of Appeal to Judge Herron’s Chambers,
his receptionist confirmed that the pendancy of my motions (the above,
plus that supplementing the record) hadn’t changed. Illustrative
of continued activity of the billboard case/controversy in PA and nationally–and
continued activity of my efforts to pressure the Attorney General to act
thereupon—is this letter sent to Mr. Fisher a fortnight ago, to which he
has yet to respond. Of course, if Judge Herron acts favorably upon
my Reargument/Reconsideration Motion, that sent to the Commonwealth Court
could become mooted. Otherwise, not withstanding the fact that you
failed to respond to the former, I would ask that you feel free to call
me if any further clarification is desired. I recognize I am still
functioning pro se, but this status needn’t stop you from communicating
directly rather than drawing incorrect inferences.