Mr. Christopher Todd White
and
Mr. James Vernon Schneider
Dear Gentlemen:
I am the attorney for ONE Institute, the International Gay and Lesbian Archives, a California non-profit corporation ("ONE Institute"). I am writing to demand return of the materials which you removed form its 909 West Adams Blvd. archive on or about December 24, 2001.
As I am sure you are aware, the materials you removed — which we believe amount to over 100 boxes and over 20 four-drawer file cabinets with materials — comprise a wide range of valuable historical documents relating to the gay and lesbian community. These materials belong to and are the property of ONE Institute. ONE Institute's right of ownership of these materials is based on several grounds, including, without limitation, the 1967 Agreement of Settlement in the lawsuit entitled One Incorporated vs. Slater, Los Angeles Superior court Case No. 864824, ONE Institute's rescue and preservation of documents after Don Slater's death in 1997, and agreements between ONE Institute and HIC as commemorated in the minutes of ONE Institute as well as other documentation and multiple witness statements.
We understand that you contacted Cal State Northridge's library to ask if it would accept a donation of the materials. We contacted the library, made the library aware of our claim of ownership, and have recently been informed by an attorney representing the University that the library will not accept a donation of the materials from you.
If these materials are not promptly returned to ONE Institute, we will have no alternative but to commence a legal action against you to obtain a court order compelling you to return the documents, as well as compensatory and punitive damages and costs of suit. I trust you will reconsider your position in this matter and conclude that the adverse publicity that such a lawsuit would create — both within and outside the university community — could be harmful. And I can assure you that, based upon my understanding of the facts, this is a case in which a court would hold you liable for substantial punitive damages if you persist in refusing to return the materials. Any damage judgement could be collected from your bank accounts, or result in a lien being placed on any real property you own.
Please contact me at your earliest convenience to arrange for the return of the materials. I look forward to your prompt response.
Sincerely,
Allen M. Katz
cc: Lynn Sipe, ONE Institute
