Free Letter - District Court of Delaware - Delaware

, Case 1:05-cv—00880-G|\/IS Document 14 Filed 07/21/2006 Page 1 of 1
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July 21, WEB; wviw.cE2|l1.cocl
Via CM/ECF and Hand-·Delive1jy
The Honorable Kent A. Jordan
United States District Court of Delaware
844 N. King Street
Wilmington, DE l980l
RE: St. Paul Travelers Companies, et ol. v. Waymr, Inc.
CA. No. O5—88O (KA.}?
Dear Judge Jordan:
I write to advise the Court: of an issue that has come to my attention subsequent to the case
scheduling conference on July 6, 2006. As Your Honor may be aware, at the time of the call my firm
had only recently been retained by Specialty Service Contractors, loc. (“Specialty"), a third party
defendant in the instant matter. At the time of the call, l did not have a complete understanding of
the scope of the claims and defenses Specialty will pursue in this action. During the conference, the
Court assigned my client 4 hours to present its case based, in part, on my misunderstanding that
Specialty would be a minor player in this litigation-
Subsequent to the call, l have been able to review relevant documents and discuss the case in
depth with my client. On behalf of Specialty, l intend to tile an answer to the third party complaint
and claims against Daisy Construction, Co. and St. Paul Insurance, Co. In light of these
developments, I respectfully request that the Court increase Specialty’s allotment of time to present
its case. One solution may be to afford Specialty the benefit ofthe full fourth day that the Court has
set already aside for this case. l have spoken with opposing counsel but could not reach an
agreement. Consequently, I request the Court schedule a brief teleconference to re-visit the issue of
trial time as it relates to my client.
Counsel is available at the call ofthe Court to discuss this issue further.
Res ctfully submitted,
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A ott G. Wilcox
ec: James D. Heisman, Esq. (via Hand-Delivery Sc CM/EC?}
Kevin W. Goldstein, Esq. (via CM/ECP}
Robert K. Beste, Jr., Esq. (via CM/EC?}
Gary W. Aber, Esq. (via CM/ECP)
Clerk of the Court (via l~land—Delivery & CM/ECE)
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