Free Answering Brief in Opposition - District Court of Delaware - Delaware

H /,-4 Case 1 :04-cv-01540-GIVIS Document 60-5 Filed 09/13/2005 Page 1 of 1
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KLINE & SPECTER
A PROFESSIONAL CORPORATION
Arronuavs AT LAW
THE NINETEENTH FLOOR
l5E5 LOCUST 5'TREET
PHILADELPHIA, PENNSYLVANIA IQIOE
Jost-iuAR.vAN NAARDEN E'5'7?2"°°°
FAX: El5e77E‘-l359
June 9, 2005
Via Fax No.308-658-8111
Mason Turner, Esquire
Prickett, Jones & Elliott, P.A.
1310 King Street
Wilmington, Delaware 19899
RE: Debbie Bailey
Dear Mr. Tumer:
I am in receipt of your fax dated June 8, 2005. In reference to your discovery requests, as
soon as I am in receipt of the authorizations that were sent out to the Baileys, I will forward the
same to you so that you can obtain the medical records for Demetria and the tax returns for
Debbie Bailey.
In your letter, you also indicated frustration in setting up the depositions in this case.
Presently 1 have in my possession eight (8) letters requesting depositions of the Defendants and
the nurses. I have repeatedly asked for dates from your office and I have supplied you with
available dates. Your responses range from offering a Saturday deposition to supplying us with
a date for a deposition with only one or two weeks notice.
I understand that scheduling these depositions has been frustrating and difficult on both
sides. However, I am still optimistic that our offices will be able to schedule these depositions
within the deadlines prescribed by the Court.
lf you have any questions, please contact me. /
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Very t_. yours,
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OSHUA VAN NAARDEN
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cc: Stephen B. Potter, Esquire