Free Letter - District Court of Delaware - Delaware

Case 1:07-cv-00071-MPT

Document 20

Filed 10/04/2007

Page 1 of 2

MARTIN D. HAVERLY ATTORNEY AT LAW Two East 7th Street Suite 201 Wilmington, Delaware 19801 Licensed in Delaware and Pennsylvania Telephone (302)654-2255 Facsimile (302)654-0175

October 4, 2007 Via E-Filing The Honorable Mary Pat Thynge United State District Court 844 North King Street Wilmington, DE 19801 RE: Benjamin E. Jackson, Sr. v Ursuline Academy C.A. No. 07-71-MPT Plaintiff's Interim Status Report

Dear Judge Thynge: The parties have exchanged Initial Disclosures and Plaintiff has served a First Set of Interrogatories and First Request Production on Defendant. Defendant sent Requests for Production to Plaintiff yesterday. A Mediation is scheduled with Your Honor on Tuesday, October 16, 2007. Unfortunately, to date Defendant has not provided Answers and Responses to the outstanding discovery served by Plaintiff, and the Defendant's Initial Disclosures were only provided in September 2007 and do not identify the topics which can be provided by the witnesses identified by Defendant. Depositions will be scheduled after Plaintiff receives the outstanding discovery. After speaking with opposing counsel, I am confident that the outstanding discovery and more precise Initial Disclosures will be provided to Plaintiff shortly. I do not anticipate there will be a difficulty concerning the scheduling of depositions because the universe of witnesses is less than typical for an employment discrimination case. However, the expert reports will need to be pushed off because Plaintiff has not yet received from Defendant documents concerning economic loss. I suggest that the new date for

Case 1:07-cv-00071-MPT

Document 20

Filed 10/04/2007

Page 2 of 2

The Honorable Mary Pat Thynge October 4, 2007 Page 2 expert reports be Wednesday, November 14, 2007 with rebuttal reports due on December 14, 2007. Any mop up expert depositions could take place thereafter. Respectfully submitted, /s/Martin D. Haverly Martin D. Haverly MDH/acs cc: Vincent A. Bifferato, Jr., Esquire (via e-filing) The Neuberger Firm Benjamin E. Jackson, Sr.