Free Letter - District Court of Delaware - Delaware

Case 1 :04-cv-01488-JJF Document 67 Filed O4/05/2007 Page 1 of 2
ROSENTHAL, MONHAIT Ea GODDESS, P. A.
ATTORNEYS AT LAW
SUITE 1401, 919 MARKET STREET
P. O. BOX 1070
JOSEPH A. ROSENTHAL WILM[N0T0N) DELAWARE 1909900,0 TELEPHONE (som eee-4433
NORMAN M. MONHAIT FACSIMILE <;—>c2> ess-yea?
JEFFREY s. GODDESS
CARMELLA F. KEENER
EDWARD E. ROSENTHAL
JESSICA ZELDIN
April 5, 2007
VIA CM/ECF and HAND DELIVERY
The Honorable Joseph J. Farnan, Jr.
United States District Court
844 N. King Street
Lock Box 27
Wilmington, DE 19801
Re: Robert V. Townes, IV v. Tra11sU11i0n, LLC and TrueLi11k, Inc.,
D. Del., C.A. N0. 04-1488-JJF
Dear Judge Farnan:
I am pleased to enclose for the Court’s consideration the parties’ Stipulation of
Settlement and supporting papers. If Your Honor finds the papers to be satisfactory, I
would be glad to work with Ms. Krett to coordinate a date for hearing on the proposed
settlement that is convenient to the Court and the parties. Because certain dates in the
Hearing Order and the Notice will be determined based on the hearing date, we will
submit a completed copy of the proposed scheduling order with those dates filled in after
a hearing date has been set. `
Also, for the Court’s infomation, and in follow up to the telephonic status
conference call of March 27, 2007, we remind the Court that pending in the U.S. District
Court for the District of Delaware is a putative class action captioned Steven G. Millett,
et. al. v. TrueLink, Inc., Case No. 05-599-SLR (the "Millett Action"), which has been
brought against one of the defendants in the above-referenced action. Qc; Document No.
32, Letter to Peter T. Dalleo, dated December 19, 2005. Because the enclosed Stipulation
of Settlement for the above—referenced matter excludes from the proposed settlement
class those individuals who are named plaintiffs in any other action pending against the

Case 1:04-cv-01488-JJF Document 67 Filed O4/05/2007 Page 2 of 2
The Honorable Joseph F. Farnan, Jr.
April 5, 2007
Page 2
defendants (Section 2.24(v)), the claims of the named plaintiffs in the Millett Action are
not affected by the proposed settlement. The claims of the individuals in the uncertified
class alleged in the Millett Action could be affected, however, if those individuals choose
not to opt-out of the settlement. I am unaware of any other pending cases which would
be affected by the proposed settlement.
Respectfully submitted,
/s/ Carmella P. Keener
Carmella P. Keener (DSBA No. 2810)
cl Attorneys for Plaintgf Robert V T owrzes, I V
CPK/jls
Enclosure
cc: William M. Lafferty, Esquire (via CM/ECP)
Michael L. McGlamry, Esquire (via CM/ECE)