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

Case 1 :04-cv-01540-GIVIS Document 60-4 Filed 09/13/2005 Page 1 of 1
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Arronuzvs AT LAW
THE NINETEENTH FLOOR
l5E5 LOCUST STREET
PHILADELPHIA, PENN5YLVANtA IQIOE
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FAX: 2 f5-7 72-I 359
April 27, 2005
Mason Turner, Esquire
Prickett, Jones & Elliott, P.A.
1310 King Street
Wilmington, Delaware 19899
RE: Debbie Bailey
Dear Mr. Turner:
This letter is in response to your letter dated April 14, 2005. We do not currently have
possession of any of Debbie Bailey’s tax returns. If you provide an IRS authorization, I will
forward it to Gladys Bailey for her signature. After consulting with the Bailey family, it is clear
that they do not know the whereabouts of William Hicks.
To date, we have been fully compliant in setting up the Depositions of the Plaintiffs and
answering Defendants lnterrogatories. Despite our efforts to cooperate, we still have not received
any answers to our discovery requests or dates certain for the Depositions of Dr. Emery or Dr.
Lehman.
lf we do not receive the discovery answers and the dates for the Defendants Depositions
within twenty (20) days, we will have no choice but to tile the appropriate Motion.
Very ly yours,
..._...-·"
JOSHUA VAN NAARDEN
J VN/ckp
cc: Stephen B. Potter, Esquire