Free Letter - District Court of Delaware - Delaware

Case 1 :04-cv-01540-GIVIS Document 62 Filed 09/23/2005 Page 1 of 2
PRICKETT, JONES & ELLIOTT
A PROFESSIONAL ASSOCIATION
1310 KING STREET, Box 1328
DOVER OFFICE PENNSYLVANIAOFFICE
11 Nomu srATE smear TEL; (302) 888-6500 217 WESTSTATE STREET
l°.§Y€‘§.s§€.L?.‘?}. FAX: (302) 658-8111 "E"“l‘i.T_Fi§iL§’Z*§E;§$ "““
FAX: (302) 674-5864 http://WWW·Prickctt.c0In FAX: (610) 444-9273
Writer's Direct Dial: (302) 888-6508
Writer's Telecopy N umben (302) 888-6549
Writer's E-Mail Address: [email protected]
September 23, 2005
Via Electronic Filing — District C0urt
The Hon. Gregory M. Sleet
United States District Court Judge
844 King Street
Lock Box 19
Wilmington, DE 19801
In re: Debbie Bailey v. Bayhealth Medical Center, Inc., et. al.
C A. N0. 04-1540-GMS
Dear Judge Sleet:
In connection with Defendants' Motion to Compel Discovery, which we are scheduled to
discuss with Your Honor on Monday morning, September 26, 2005 at 9:00 a.m. by
teleconference, I prepared a Joint Agenda which I sent to Plaintiffs' cormsel as being the issues
remaining for resolution by the Court in connection with my motion. Those issues are as
follows:
1. Whether the Plaintiffs are obligated to file properly verified interrogatory answers
pursuant to Rule 33;
2. Whether the Decedent's federal and state tax returns must be produced by a date
certain, or, in the alternative, an authorization permitting those returns to be obtained from the
Delaware Division of Revenue must be provided by a date certain;
3. Whether Plaintiff must provide infomation concerning special damages being
claimed (interrogatory 11) by a date certain, or be barred from presenting such claim;
4. Whether Plaintiffs must provide infomation concerning the Decedent's spending
and savings (Interrogatories 25 and 26) by a date certain or be barred from presenting a claim for

Case 1:04-cv—01540-G|\/IS Document 62 Filed 09/23/2005 Page 2 of 2
The Hon. Gregory M. Sleet
Page 2
September 23, 2005
what the Decedent would have earned, saved and left but for her alleged wrongful death pursuant
to 10 Del.C. § 3724;
5. Whether Defendant must be awarded the reasonable costs incurred in obtaining an
Order. .
I heard back yesterday afternoon from Mr. Van Naarden's office sending me the
document which I am attaching to this letter "Plaintiffs' Joint Agenda." I attempted to call Mr.
Van Naarden about this, but he was unavailable and I spoke to his secretary late yesterday
aftemoon and explained to her that the items which they had sent me do not appear related to the
pending motion, and that frankly I do not know what they relate to and was not certain that Your
Honor would welcome this doctunent. I received a message back from Mr. Van Naarden's
secretary yesterday evening indicating that they would like this document submitted and I am
therefore appending it to this submission.
I will be placing the conference call to the Court and Mr. Van Naarden Monday moming
at 9:00 a.m.
Respectfully, /
un},
M , ./r·.
dawn E //4»1,¤.e,$ {MW,
METjr/jb MASON E. TURNER, JR.
Attachment
cc: Joshua Van Naarden, Esq. (w/ Attachment)
Stephen B. Potter, Esq. (w/ Attachment)