National Paralegal Inst. Coalition - Page 5

          that respondent would defer any action on the application until               
          November 28, 2002.  On December 9, 2002, following the expiration             
          of the extended deadline, petitioner requested by letter an                   
          additional 10-day period to respond.  On December 18, 2002, in                
          presumably intersecting mailings, both respondent and petitioner              
          sent each other letters of even date:  respondent notified                    
          petitioner that its application was administratively closed,                  
          although the application review would be reopened without an                  
          additional user fee if the requested information enumerated in                
          the September 27, 2002, letter was submitted within 90 days.                  
          Petitioner’s correspondence provided additional information                   
          correlating to the itemized requests in the September 27, 2002,               
               On December 31, 2002, respondent sent petitioner a letter                
          (the disputed letter) containing a litany of particular                       
          insufficiencies outstanding in petitioner’s application, which                
          included, among other things, conflicts inherent in its                       
          governance structure denoting private foundation status and                   
          petitioner’s failure to adopt related prophylactic provisions in              
          its organic documents, as well as information about petitioner’s              
          fundraising activities, membership details, and operations.  The              
          shortcomings listed in the disputed letter reflect respondent’s               
          review and assimilation of petitioner’s responses to the                      
          September 27, 2002, letter included in its letter of December 18,             

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Last modified: May 25, 2011