Free Letter - District Court of Delaware - Delaware

Case 1:07-cv-00410-MPT

Document 22

Filed 09/07/2007

Page 1 of 1

DOUGLAS A. SHACHTMAN
& A S S O C I A T E S
SUITE 302 1200 PENNSYLVANIA AVENUE WILMINGTON, DELAWARE 19806 (302) 655-1800 TELECOPIER (302) 655-5244

ATTORNEYS AT LAW
email [email protected] www.lawyers.com/shachtman

September 7, 2007

Magistrate Judge Mary Pat Thynge U.S. District Court of Delaware 844 North King Street, Room 4209 Lock Box 8 Wilmington, DE 19801 RE: Dear Judge Thynge: With regard to the September 12, 2007 scheduling call, and the scheduling order to be submitted before that, the parties believe that a recent development may make them premature. (Eastern's counsel is out-of-town and has not taken a position.) Since Plaintiff filed her Complaint pro se, she has retained the undersigned. I have circulated an Amended Complaint to Defendants' counsel for their review, with a proposed Stipulation granting Plaintiff leave to file the Amended Complaint, subject of course to Your Honor's approval. If Defendants will not so stipulate, then Plaintiff will file a motion for leave to amend. Defendants have to consider what position they will take on the Amended Complaint and whether or not the case dispositive motions of Defendants Comcast and Eastern are rendered moot in their present form. Therefore, the parties jointly request that the Court defer the scheduling conference until the status of the pleadings is determined and completed. Talley v. Comcast Corporation, et al. C.A. No. 07-410 (***)

Respectfully yours,

/s/ Douglas A. Shachtman
DOUGLAS A. SHACHTMAN DAS/sas cc: Thomas C. Grimm, Esq. C. Scott Reese, Esq. James W. Parrett, Jr., Esq Jameson A.L. Tweedie, Esq. Chad Michael Shandler, Esq.
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