Free Letter - District Court of Delaware - Delaware

Case 1:07-cv-00160-LPS Document 40 Filed 04/15/2008 Page 1 of 1
WHITEFORD, TAYLOR & PRESTON L.L.C.
1220 N. MARKET STREET, SUITE 608 tiM;t·tM¤mz, my
WILMINGTON, DE 19801 ¢<>¤·¤M¤M» M¤>*
FALLS CI IURCI I, VAT
DANIEL A_ GIIIFFITII MAIN TELEPHONE (302) 355-4144 TOWSON, Mor
"’““"""" FACSIMILE (302)-661-7950 wAs111Nc;ToN, oct
i>1m2<;T1,1N12 (502) 482-8754 \V|LMING'l`ON, DIE
u1msc*1‘rAx (302) 258-0785
I)Grii`iirl1QQxv1plaxv.c0n1 WWW.Wl`}’lA\V.COh1 f
(800) 987-8705
April 15, 2008
The Honorable Leonard P. Stark 9
United States District Court
District of Delaware
844 King Street
Wilmington, DE 19801
Re: Banks v. City of Dover, et al, AL., 07-160-LPS
Interim Status Report
Dear ludge Stark:
On behalf of the defendants, we agree with the representations set forth in the
April 10, 2008 letter status report found by plaintiffs counsel, Richard R. Wier, Ir.,
Esquire (docket entry #39 and attached) and would therefore join in Mr. Wier’s request
that the April 16, 2008 telephonic status conference be taken off the Court’s calendar.
By way of amplification, while Mr. Wier graciously refrained from assigning
blame, the delay in working through the proposal that the parties have discussed I
following mediation has been on the defense side, as a consequence of the reassignment
of the handling of this claim internally by the defendants insurance carrier. We
anticipate that the response to the proposal will be forthcoming very shortly and we
will of course, promptly advise the court of any relevant updates.
Thank you for your attention to this matter. 9
Respectfully submitted,
{sg Daniel A. Griffith
Daniel A. Griffith
(Delaware Bar I.D. #4209) i
rc I
Attachment I
*Wliitejbrd, Taylor rmdPrestm1 L.L.C. is a limited liahilily mmprmy. Our ojjices outside of Delaware operale umlur a separate Marylami limited liability partimrsliip, Lwiitefunl, Taylnr 5* Preston LLP.

Case 1:07-cv-00160-LPS Document 40-2 Filed O4/15/2008 Page1 of 2

Case 1 :07-cv-00160-LPS Document 40-2 Filed 04/15/2008 Page 2 of 2
RICHARD R. WIER, JR., P.A.
Arroruvsv AT mw
rzrcrrrurn it wrsn. nv
-— w?3t’.?~%l%N$3t£r$l§%§%°.a m 5;:3;; ggggggg
mrcrrsur n. Arsrsw ww-Wi¤r¤¤w·=¤¤¤
[email protected]
MAllen@Wierl¤w.ccm
*ALSO ADMITTED IN PA
April 10,2008
Via CM/ECF
The Honorable Leonard P. Stark
United States District Court
District of Delaware
844 King Street
Wilmington, Delaware 19801
Re: Banks v. City of Deover, et. AI., 07-160-LPS
Interim Status Report
Dear Judge Stark:
This letter is to provide you with an interim report on the nature of the matters in issue and the progress
of discovery to date as ordered.
The parties participated in mediation in the above referenced case on January 3, 2008. Unfortunately,
the parties were unable to resolve the matter at mediation. At the suggestion of the Honorable Judge Thynge and
with the agreement of counsel Plaintiffs sent a proposal to Defendants to resolve the matter on February 6, 2008.
Plaintiffs to date have not received a response to their proposal. However, we will attempt to continue to work
with defense counsel to resolve this matter and willkeep the Court apprised of any developments.
The discovery deadline in this case is June 6, 2008. The parties have participated in limited discovery at
this point because of the continued efforts to resolve this matter. Plaintiffs, however intend to notice the
depositions ofthe Defendants within the next week if the matter can not be resolved.
There are no issues that require the Court’s attention at this time. The parties will continue to work
together to resolve any issues without action from the Court. Therefore, Plaintiffs at this time do not believe that
there is anything to add at the status conference scheduled for April 1 6, 2008 and therefore request it be taken off
the Court’s calendar.
Respectfully submitted,
/s/ Richard R. Wier, Jr., Esquire
/s/ Michele D. Allen, Esquire
RICHARD R. WIER, JR. ,
/s/Michele D. Allen
Delaware Bar. No. 4359
Two Mill Road, Suite 200
Wilmington, DE 19806
302-888-3222
Counsel for Plaintiffs