One Atlantic Center

1201 West Peachtree Street

Atlanta, GA 30309-3424

404-881-7000

Fax:404-881-7777

www.alston.com

Charles H Morgan

VIA FACSIMILE - (202) 606-5409

and U.S. First Class Mail

Direct Dial: 404-881-7187

December 9,2008

E-mail: charlie.morgan@alston.com

The Honorable Dennis L. Phillips

Occupational Safety and Health Review Commission

One Lafayette Center

1120 20th Street, NW - 9th Floor

Washington, DC 20036-3419

Re: Secretary ofLabor v. Imperial-Savannah, L.P. et ai, OSHRC Docket No.

08-1104

Dear Judge Phillips:

Enclosed are an original and one copy ofRespondent's Objection to Complainant's

Motion for Extension ofTime to Serve Answers and Objections to Respondent's First

Interrogatories and First Request for Production ofDocuments. I would appreciate it if you

would have your office stamp the copy as received and return it to me in the enclosed, selfaddressed stamped envelope. We have served a copy ofthis Objection on counsel for

Complainant. Thank you.

Charles H. Morgan

CHM:chm

cc: Sharon D. Calhoun, Esq. (w/encl. via facsimile)

Karen E. Mock, Esq. (w/encl. via facsimile)

Christopher D. Helms, Esq. (w/encl. via facsimile)

Matthew J. Gilligan, Esq.

LEGAL02/3 I058770v I

Atlanta. Charlotte. Dallas· Los Angeles· New York· Research Triangle. Silicon Valley· Ventura County. Washington, nc.
UNITED STATES OF AMERICA

OCCUPATIONAL SAFETY AND HEALTH REVIEW COMMISSION

SECRETARY OF LABOR,

IMPERIAL SUGAR COMPANY;

IMPERIAL-SAVANNAH, L.P.

Docket No. 08-1104

Respondents.

Complainant,

v.

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RESPONDENT'S OBJECTION TO COMPLAINANT'S MOTION FOR EXTENSION OF

TIME TO SERVE ANSWERS AND OBJECTIONS TO RESPONDENT'S FIRST

INTERROGATORIES AND FIRST REQUEST FOR PRODUCTION OF DOCUMENTS

Respondent Imperial-Savannah, L.P. respectfully objects to Complainant's request for

thirty (30) additional days in which to respond to Respondent's discovery requests. By Order

dated September 3, 2008, Complainant has already been afforded an additional thirty (30) days

in which to file her Complaint, to which Respondent did not object based on Complainant's

request that Complainant's counsel needed additional time in which to receive and review the

file in this matter. Respondent objects to Complainant's request for an additional thirty (30) days

based on Respondent's concern that the such additional time will prejudice Respondent's ability

to complete discovery in a timely fashion.
c

Respectfully subn1itted, this 9th day of December, 2008.

Charles H. Morgan

charlie.morgan@alston.c m

Matthew J. Gilligan

matt.gilligan@alston.com

Jeremy D. Tucker

jeremy.tucker@alston.com

ALSTON & BIRD LLP

1201 West Peachtree Street

Atlanta, Georgia 30309-3424

(404) 881-7000

FAX: (404) 253-8757

Attorneys for Respondents

- 2-
UNITED STATES OF AMERICA

OCCUPATIONAL SAFETY AND HEALTH REVIEW COMMISSION

SECRETARY OF LABOR,

IMPERIAL SUGAR COMPANY;

IMPERIAL-SAVANNAH, L.P.

Docket No. 08-1104

Respondents.

Complainant,

v.

)

)

)

)

)

)

)

)

)

)

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CERTIFICATE OF SERVICE

This is to certify that I have this date served a copy ofthe within and foregoing

RESPONDENT'S OBJECTION TO COMPLAINANT'S MOTION FOR EXTENSION OF

TIME TO SERVE ANSWERS AND OBJECTIONS TO RESPONDENT'S FIRST

INTERROGATORIES AND FIRST REQUEST FOR PRODUCTION OF DOCUMENTS by

facsimile and certified U.S. Mail, return receipt requested with adequate postage affixed thereon,

addressed as follows:

Sharon D. Calhoun, Esq.

Karen E. Mock, Esq.

Christopher D. Helms, Esq.

Office ofthe Solicitor

U.S. Department of Labor

61 Forsyth Street S.W.

Room 7TI0

Atlanta, Georgia 30303

This 9th day of Decenlber, 2008.