Free Letter - District Court of Delaware - Delaware

. Case 1:05-cv-OO873—GI\/IS Document 15 Filed O2/24/2006 Page 1 of 3
KLETT ROONEY LIEBER & SCHORLING
A PROFESSIONAL CORPORATION
ATTORNEYS AT LAW
THE BRANDYWINE BUILDING
1000 WEST STREET, SUITE 1410
WILMHQGTON, DELAWARE 19801-1397
Telephone: (302) 552-4200
Mary F. Caloway FACSIMILE: (302) 552·4295
(302) 552»4209 E·MAIL: [email protected]
February 24, 2006
BY ELECTRONIC FILING
The Honorable Gregory M. Sleet
United States District Court
844 King Street
Wilmington, DE 19801
Re: DDJ Capital Management, LLC v. J. William Uhrig, et al.
Civil Action No. 05-873-GMS
Dear Judge Sleet:
Yesterday, the parties filed a stipulation for an extension of the time for plaintiff to file an
answering brief to the motion to dismiss that was filed by the defendants on February 15, 2006.
While the stipulation itself did not set out the reason for the agreed extension, counsel had
prepared an accompanying letter, a copy of which is attached hereto, that had stated the reason.
Through inadvertence, however, we failed to electronically file the accompanying letter.
The reason for the requested extension is that both firms that presently represent the
plaintiff, Klett Rooney Lieber & Schorling and Akin Gump Strauss Hauer & Feld LLP, have
discovered that they have conflicts of interest that prevent them from continuing to represent the
plaintiff in this action. The conflicts of interest presented themselves as a result of developments
that occurred after this action had already been instituted.
The parties stipulated to the extension of the time for the plaintiff’ s answering brief to
March 29, 2006 to enable new counsel for the plaintiff to enter their appearances, to familiarize
themselves with the case, and to prepare and file the plaintiff’ s answering brief. The plaintiff has
just made arrangements with Arnold M. Weiner, Esq., of the Baltimore firm of Weiner &
www.klettr00ney.c0m
PITTSBURGH, PA HARRISBURG, PA PHILADELPHIA, PA WILMINGTON, DE NEWARK, NJ
KRLSWILM: 65096

Case 1:05-cv-OO873—GI\/IS Document 15 Filed O2/24/2006 Page 2 of 3
February 24, 2006
E Page 2
Weltchek, to come into the case, but Mr. Weiner will need time to secure local counsel and to
learn the case. Under these circumstances, we believe that the requested extension is reasonable.
Having now made the reason for the stipulated extension known to the Court, we
respectiully request that the Court reconsider the stipulation and enter an Order approving it.
Counsel is available at the Court’s convenience to answer any questions.
Respectfully Submitted,
Mary F. Cal ay (#3059
For KLETT ROONEY LIEBER & SCHORLING
A PROFESSIONAL CORPORATION
cc: Lisa Whittaker (via-electronic mail)
www.ldettr00ney.c0m
PITTSBURGH, PA HARRISBURG, PA PHILADELPHIA, PA WILMINGTON, mz NEWARK., NJ
Kizrswirm; 65096

. Case 1:05-cv-00873—GI\/IS Document 15 Filed 02/24/2006 Page 3 of 3
KLETT ROONEY LIEBER & SCHORLING
A PROFEss1ONAL CORPORATION
ATTORNEYS AT mw
THE BRANDYWINE Burwmc
1000 WEST STREET, SUITE 1410
WILMINGTON, DELAWARE 19801·1397
Telephone: (302) 552-4200
Teresa I(.D. Currier FACSIMILE: (302) S52·4295
(302) 55Z·4220 E-MAIL: [email protected]
February 23, 2006
BY ELECTRONIC FILING
I The Honorable Gregory M. Sleet
United States District Court
844 King Street
Wilmington, DE 19801
Re: DDJ Capital Management, LLC v. J. William Uhrig, et al.
Civil Action No. 05-873-GMS
Dear Judge Sleet;
Enclosed is a proposed stipulation to extend until March 29, 2006 the time for the
plaintiff to respond to the motion of the defendants J. William Uhrig, Steven Langman and
Robert Chambers to dismiss the complaint. Counsel for the defendants has agreed to this
request.
Plaintiff respectfully requests that the Court grant this proposed enlargement because
present counsel for plaintiff must withdraw their appearances due to potential conflicts of interest
and it is necessary for counsel to enter their appearances for the plaintiff and to familiarize
themselves with the case.
Teresa K.D. Currier (#3 )
Enclosure
cc: Peter T. Dalleo, Clerk (By Hand; w/encl.)
Lisa Whittaker (By e-filing; w/encl.)