Free Letter - District Court of Delaware - Delaware

Case 1:05-cv—O0916-TNO DoEump@§,;;,CEFi|ed 12/O4/2007 Page 1 of 2
O E
JOHN M. LAROSA
Two EAST 7TH STREET, SUITE 302
WILMINGTON, DELAWARE 19801 -3707
PHONE.: (302) 888-1290 LICENSED IN DE, PA, AND NJ
FAX: (302) 655-9329 INTERNET: WWW.LAROSALAW.COM
December 4, 2007 Via CM/ECF Filing
The Honorable Thomas N. O`Neill. Jr.
United States District Court for the Eastern District of Pennsylvania
U.S. Courthouse
601 Market Street, Room # 4007
Philadelphia, PA 19106-1714
RE: Neuberger v. Gordon, et al., Civil Action N0. 05-916 TNO (D.Del.)
Plaintiffs Rcguest to Lift Stay
Dear Judge O’Neill:
l have entered my appearance today as attorney for Plaintiff Thomas S. Neuberger in the
above captioned action. This case was tiled on December 29. 2005. (D.l. 1). On June 26, 2006,
the Court stayed this case pending resolution of the criminal proceedings then pending against
defendants Gordon and Freebery. (D.l. 15).
Those defendants have pled guilty to some of the criminal charges against them and the
remainder have been dismissed. As a result of these events, the rationale used by the Court to
stay this case - including the status of the criminal proceedings. consent by all parties pending the
resolution of the criminal matters, and defense concems about self-incrimination - no longer
applies. Indeed. the public interest, the Court’s interest and plaintiff s interest in resurrecting this
long-stayed case now dramatically have increased. Furthermore. four other previously stayed
civil cases involving those defendants. Reves v. Freeberv. C .A. No. 02-1283; Riddell v. Gordon.
C.A. No. 04-01201: Tobin v. Gordon. C.A. No. 04-01211; and Jamison v. Gordon. C.A. N0. 04-
01568. have resumed with the Court ordering Rule 16 scheduling teleconferences for each of
those cases for this Friday, December 7, 2007.
Accordingly, plaintiff here too respectfully requests that the stay be lifted here so that
defendants may file their Answer, a scheduling order may be put in place. and discovery may
proceed.
Respectfully submitted,
/s/ John M. LaRosa
Attorney for Plaintiff

Case 1:05-cv—O0916-TNO Document 17 Filed 12/O4/2007 Page 2 of 2
The Honorable Thomas N. O`Neill, Jr.
United States District Court for the Eastern District of Pennsylvania
December 4. 2007
Page 2
cc: Charles E. Butler. Esquire (via CM/ECF)
Thomas S. Neuberger, Esquire (via hand delivery)