Free Letter - District Court of Delaware - Delaware

Case 1 :05-cv-00879-SLR Document 6 Filed 12/20/2005 Page 1 of 2
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Rica-iAR¤s, Lmrrow 6. FINGER
A PROFESSIONAL A,55OClATION
ONE RODNEY SQUARE
920 NORTH Kms STREET
W,,_,_, _j_ WADE WILMINGTON, DELAWARE i9&s0i DRECT D"°"· NUMBER
DIAIJECTOR (.302) 65 l—77OO
FAX caoai esi-7701
WWW.RLF.CC>M
December 20, 2005
BY HAND DELIVERY O 5 8 7 9
Dr. Peter T. Dalleo
Clerk, U.S. District Court
844 North King Street
Wilmington, DE 19801
Re: Emergency Relief: Pike Electric Corporation and Pike Electric, Inc.
v. Dubea
Dear Dr. Dalleo: 2
I write on behalf of Pike Electric Corporation and Pike Electric, lnc. (collectively
"Pike"), the plaintiffs in the captioned action. For the Court’s convenience, I have enclosed
herewith copies of the Verified Complaint, Summons, Motion for Preliminary injunction and for
Expedited Discovery, the Declaration of Eric Pike, a proposed form of Order granting
preliminary injunction and a proposed form of Order expediting discovery and setting expedited
brief schedule. Because of the urgency of Pike’s claims and the continuing irreparable harm that
Pike is suffering, Pike respectfully requests that this matter be assigned promptly to the first
available judge so that Pike’s Motion for Preliminary Injunction and Expedited Discovery may
be heard promptly. As set forth in more detail in the enclosed submissions, the defendant has
acted and unless enjoined will continue to act in breach of his contractual and common law duty
to Pike. More particularly, defendant has been acting in breach of a lawful covenant not to
compete and a covenant precluding his use of Pike’s proprietary and confidential business
information and has tortiously interfered with the contractual relations between Pike and its
employees and with the business relations between Pike and its customers. The defendant’s
actions are causing irreparable harm 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 Injunction. The requests
for a preliminary injunction and expedited discovery are amply supported by the papers enclosed
herewith.
Pike will cause defendant to be seryed with such papers by registered mail, as is
required by the Employment Agreement between plaintiff Pike Electric, Inc. and defendant. In
addition, Pike will cause the Complaint, the preliminary injunction motion and all supporting
RLFI-2959428-1

Case 1:05-cv-00879-SLR Document 6 Filed 12/20/2005 Page 2 of 2
Dr. Peter T. Dalleo
December 20, 2005
Page 2
papers to be delivered by ovemight delivery service to defendant. In a letter covering such
documents, Pike will request that defendant have his counsel contact Pike’s counsel forthwith.
Consistent with the foregoing, Pike respectfully requests the prompt assignment
of this matter so that Pike can present its motion for expedition at the Courl;’s early convenience.
If you should have any questions concerning the foregoing or if I can provide any
further infomation, I am available at the Court’s convenience.
Very truly yours,
éilliam J. Wade
WJW/bw
Enclosures
RLFI-2959428-l