V I R G I N I A :

         IN THE GENERAL DISTRICT COURT OF ARLINGTON COUNTY


RAM AVRAHAMI,                      :
                                   :
               Plaintiff,          :
                                   :
v.                                 :    Case No. 95-7479
                                   :
U.S. NEWS & WORLD REPORT, INC.,    :
                                   :
               Defendant.          :


        DEFENDANT U.S. NEWS' MOTION FOR PROTECTIVE ORDER
          CONCERNING PLAINTIFF'S REQUEST FOR ADMISSION

     Defendant U.S. News & World Report, Inc. ("U.S. News") hereby
moves this Court for a protective order directing that U.S. News
need not respond to the Request for Admission served by plaintiff
Ram Avrahami ("Avrahami") because written discovery is not
permitted under the rules of this Court.

     Avrahami commenced this action, complaining that by "renting"
a mailing list allegedly containing Avrahami's name, U.S. News
violated his rights and somehow caused him injury.  When U.S. News
moved to stay this action on the grounds that a declaratory
judgment action concerning the same issues was pending in the
Circuit Court of Arlington County, Avrahami opposed the motion and
insisted on a trial in the forum that he chose.  U.S. News' motion
was denied.

     With trial scheduled for February 6, 1996, Avrahami served
Plaintiff's Request for Admission, a copy of which is attached as
Exhibit A, on January 16, 1996.

     The service of requests for admission is authorized by Rule
4:11.  Rule 4:0 specifically limits the application of Part Four of
the Rules, however, to Circuit Courts.  The only civil discovery
that is available in this Court is a subpoena duces tecum in
accordance with Va. Code # 16.1-89.  Thus, Avrahami cannot serve
requests for admission in the forum that he selected.  If he wanted
to conduct pretrial discovery, he should not have opposed U.S.
News' earlier motion.

                           CONCLUSION

     For the foregoing reasons, defendant U.S. News & World Report,
Inc. respectfully requests that this Court enter an order that U.S.
News need not respond to Plaintiff's Request for Admission.

Dated:  February 2, 1996           Respectfully submitted,
                                   U.S. NEWS AND WORLD REPORT, INC.
                                   By Counsel


SHAW, PITTMAN, POTTS & TROWBRIDGE

By:    /s/
   David G. Fiske, VSB #14511
   Lori Vaughn Ebersohl, VSB #38302
   115 South Union Street
   Alexandria, Virginia 22314
   (703) 739-6650

   Counsel for U.S. News and World Report, Inc.


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