Free Letter - District Court of Delaware - Delaware

Case 1:06-cv—00725-Gl\/IS Document 29 Filed 11/30/2007 Page 1 of1
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OIT1S_l3H1€S LLP
James H. McMackin, III
$02.8885849
[email protected]
November 30, 2007
VIA E-FILING
The Honorable Gregory M. Sleet
I United States District Court
Federal Building
844 King Street
Wilmington, DE 19801-3570
RE: Kenneth S. Mitchell v. Wachovia Corporation, et al.
Civil Action No. 06-725 GMS
h Dear Judge Sleet:
I am writing to follow up on my letter to Your Honor and stipulation dated
November 20, 2007. Today is the discovery cut-off in this case. Case dispositive motions are
due on Friday, December 14th. The defendants anticipate filing a case dispositive motion.
Mr. Mitchell, the plaintiff, has been unavailable for his deposition on the dates
considered by the defendants due to his activation by the Naval Reserves. Mr. Mitchell's
deposition is planned by agreement of the parties for Wednesday, December 12. The plaintiff
plans to depose defendants Gauthier and Meyer. The depositions of these two defendants will
likely occur during the week of December 10 and December 17.
In order that the parties have an opporttmity to complete discovery, and that the
defendants have an opportunity to file a case dispositive motion, I respectfully request that Your
Honor consider the parties' stipulation to extend time for the completion of discovery and the
. tiling of dispositive motions.
Counsel for the plaintiff agrees with the request to extend the discovery deadline.
Respectfully submitted,
Jaml es H. McMackin, III
(Bar I.D. #4284)
JHM/jam
cc: Steven F. Mones, Esquire (w/enc.) (via e-tiling)
Devjani Mishra, Esquire (w/enc.) (via e-mail)
Clerk of the Court (w/enc.) (via e-filing)
1636092/1
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