MASSACHUSETTS COMMISSION AGAINST DISCRIMINATION

NO. 99-BEM-2634

WILLIAM SILVERSTEIN, Plaintiff

v.

MICROSYSTEMS SOFTWARE, INC., THE LEARNING COMPANY, INC., MATTEL INC, Respondents



MOTION FOR TO DEFAULT DEFENDANT THE LEARNING COMPANY, INC.


I hereby request that in accordance with 804 CMR 1.13(5)(d) the Respondent, THE LEARNING COMPANY, INC. ("TLC") be defaulted..

There was no person or attorney representing TLC at the investigative conference. TLC failed to file any type of response. The respondents Mattel and Microsystems Software filed an untimely REQUEST FOR MORE DEFINITE STATEMENT.


I respectfully implore the Commission enforce their own regulations and default The Learning Company for non-response and non-attendance. Such sanction and finding of probable cause is appropriate to this case. There is no dispute that I publicly complained of violations of MGL c.151B on my website. The respondent TLC cannot dispute that they filed, and continued, a lawsuit against me because of the complaints on the website.


Wherefore, I request that the commission default respondent TLC and make an immediate finding of probable cause.

Respectfully submitted,

WILLIAM SILVERSTEIN