Free Letter - District Court of Delaware - Delaware

Case 1 :07-cv-00271-JJF Document 33 Filed 11/O1/2007 Page 1 of 2
Fox Rothschild up
Arroaitrvs AT uiw
Citizens Bank Center, Suite 1300
919 North Market Street
PO. Box 2323
Wilmington, DE 19899-2323
rei $02.6547444 Fax 302.6%.8920
www foxrothschnlrl com
Sophia Siddiqui
Direct Dial: (302) 622-4278
Email Address: [email protected]
November l, 2007
VIA ELECTRONIC FILING
The Honorable Mary Pat Thynge
U.S, District Court for the District of Delaware
844 King Street
Wilmington, Delaware 19899
Re: Joe Gano v. Donald Mark Ehart and Spread Eagle, Inc.
Delaware District Court, C.A. N0. 07-271-***
Dear Magistrate Thynge:
As per your Honor’s request, I am writing to update the Court on the parties’ attempt to resolve
the discovery issue discussed during the Court’s status conference in this matter.
Plaintiff issued a Request for Production of Documents to Defendant Ehart requesting certain
support records from Defendant Ehart’s support proceedings in the Delaware Family Court, which
include a valuation of Defendants’ business assets at issue in this action. Additionally, Plaintiff issued a
subpoena upon the Family Court to produce these records. The Family Court filed a Motion to Quash
Subpoena on October ll, 2007. The Court decided to reserve ruling upon the Motion to Quash to allow
the parties to amicably resolve the issue.
Plaintiff s counsel is working with Deputy Attorney General Ralph K. Durstein to finalize a
confidentiality agreement that would provide Plaintiff with access to the Family Court records in
Defendant Mark Eha1t’s custody and support proceedings. The confidentiality agreement would require
the signature of both Plaintiffs and Defendants’ counsel.
However, Defendants are unwilling to sign the confidentiality agreement. Thus, Plaintiff
respectfully requests that the Court intervene and schedule a teleconference to resolve this matter.
A l°e"i*~s;,- Janie L ii iii: t atrl ls ‘a·‘rer2l"r~
California - ¤ .*.· =~ tiorica Nevada New Jersey New Vrrk Pennsylvariia

Case 1:07-cv-00271-JJF Document 33 Filed 11/O1/2007 Page 2 of 2
FOX ROJ[l'l5Cl'lllCl LLP
ATTORNEYS AT LAW
The Honorable Mary Pat Thynge
November I, 2007
Page 2
I am available at your Honor’s convenience to answer any questions.
Respectfully,
/s/ Sophia Siddiqui (#4914)
Sophia Siddiqui
cc: Richard Cross, Esquire (via hand delivery)
Tara M. DiRocc0, Esquire (via hand delivery)
Ralph K. Durstein, Esquire (via hand delivery)
Todd Nurick, Esquire
Wendy Rothstein, Esquire