Free Letter - District Court of Delaware - Delaware

Case 1 :07-cv-00271-JJF Document 31 Filed 10/24/2007 Page 1 of 2
Fox Rothschild rrp
Arrormrvs AT oiw
Citizens Bank Center, Suite 1300
919 North Market Street
PO. Box 2323
Wilmington, DE 19899-2323
Ten 3026547444 Pax 3o2.eee.ae2o
www.fo> Sophia Siddiqui
Direct Dial; (302) 622-4278
Email Address: [email protected]
October 24, 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. No. 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.
Plaintiffs counsel is currently in the process of finalizing a confidentiality agreement with
Deputy Attorney General Ralph K. Durstein that would provide Plaintiff with access to the family court
records in Defendants Mark Ehart’s custody and support proceedings. The confidentiality agreement
would require the signature of both Plaintiff s and Defendants’ counsel.
At this time, Defendants’ counsel has taken the position that these doctunents are privileged and
irrelevant to the instant litigation. Plaintiff s counsel would like to continue working with Deputy
Attorney General Durstein to finalize the confidentiality agreement, and further discuss ways to resolve
the issue with Defendants’ counsel.
Plaintiff s counsel suggests that the parties report back to your Honor within one week regarding
the status of their resolution of this issue, unless the Court prefers to speak with the parties at an earlier
time.
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Case 1:07-cv-00271-JJF Document 31 Filed 10/24/2007 Page 2 of 2
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ATTORNEYS AT LAW
The Honorable Mary Pat Thynge
October 24, 2007
Page 2
I am available at your Honor’s convenience to answer any questions.
Respectfully,
/.9/ Sophia Siddiqui (#4914)
Sophia Siddiqui
cc: Richard Cross, Esquire (via hand delivery)
Tara M. DiRocco, Esquire (via hand delivery)
Ralph K. Durstein, Esquire (via hand delivery)
Todd Nurick, Esquire
Wendy Rothstein, Esquire