Free Letter - District Court of Delaware - Delaware

Case 1:05-cv-00879-SLR Document 9 Filed 12/30/2005 Paget of2
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December 30, 2005
BY ELECTRONIC FILE AND HAND DELIVERY
The Honorable Sue L. Robinson
U.S. District Court for Delaware
844 King Street
Wilmington, Delaware 19801
Re: Pike Electric Corporation and Pike Electric, Inc. v. Dubea,
C.A. N0. 05-879-SLR
Dear Chief iudge Robinson:
I write on behalf of Pike Electric Corporation and Pike Electric, inc. (collectively,
"Pike"), the plaintiffs in the above-captioned action. On December 20, 2005, Pike tiled a
Verified Complaint and Motion for Preliminary Injunction and Expedited Discovery seeking
expedited relief for a former employee’s breach of a covenant not to compete, misuse of
confidential business information, and tortious interference with the contractual relations
between Pike and its employees and with the business relations between Pike and its customers.
That same day, Judge Jordan advised the undersigned that once the case was assigned, Pike
should send a letter to the assigned Judge regarding Pike’s pending application for expedited
discovery and reliefl
Defendant’s actions are causing irreparable harm to Pike, and unless enjoined
defendant will continue to act in breach of his contractual, common law and statutory duties to
Pike. The expedited relief which Pike seeks includes an Order expediting discovery and setting
an expedited briefing schedule on Pike’s Motion for Preliminary lnjunctionr Because of the
urgency of these claims, Pike respectfully requests that Your Honor set a time for Pike to present
its Motion for Expedited Discovery regarding Pike”s Motion for Preliminary injunction.
The same day Pike filed this action, it also served defendant with the Verified
Complaint and all motion papers by both registered mail (as required by the Employment
Agreement between piaintiff Pike Electric, lnc. and defendant) and overnight delivery service.
ln a letter covering such documents, Pike requested that defendant contact Pike’s counsel
forthwith,. Pike has yet to hear from defendant.
air 1-2963520-i

Case 1:05-cv-00879-SLR Document 9 Filed 12/30/2005 Page 2 of 2
The Honorable Sue L. Robinson
December 30, 2005
Page 2
I have enclosed copies of the Verified Complaint, Motion and Brief in Support of
Pike’s Request for Preliminary Injunction and Expedited Discovery, and Deciaration of Eric
Pike. lf you should have any questions concerning the foregoing or if I can provide any further
information, I am available at the Court’s convenience.
Very truly yours,
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William .l. Wade (#704)
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Enclosures
cc: Clerk ofthe Court (by electronic tile and hand delivery w/o enclosures)
Mick Dubea (by federal express w/o enclosures)
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