Free Letter - District Court of Delaware - Delaware

Case 1:04-cv-01488-JJF Document 32 Filed 12/19/2005 Page1 of 2
MORRIS, N1oHoLs, ARSHT & TUNNEL1.
1201 NORTH M; RKET STREET
P.O. Box 1347
WILMINGTON, DELAWARE 19899-1347
302 658 9200
WILLIAM LAFFERTY FAX
302 575 ml December 19, 2005
302 425 4679 FAX
[email protected]
VIA E-FILING
Mr. Peter T. Dalleo
Clerk of Court
United States District Court
District of Delaware
844 King Street
Wilmington, Delaware 19801
Re: Townes v. TmnsUni0n LLC, etal, C.A. N0. 04-1488 JJF
Dear Mr. Dalleo:
Pursuant to Local Rule 3.1(b), I write to inform the Court of the filing of a case
that is related to the above-referenced action, which is assigned to Judge Farnan. On August 16,
2005, 2005, a putative class action captioned Millett v. T rueLink, Inc., C.A. No. 05-599-SLR was
transferred into this District from the Federal Court in Kansas City, Missouri, and was assigned
to Judge Robinson. On December 6, 2005, the plaintiffs in the Millett case tiled a motion
seeking leave to file a second amended complaint to add certain claims against TrueLink similar
to those at issue in the above-referenced action against TransUnion and TrueLink (TrueLink is
an affiliate of TransUnion). Defendants did not oppose the motion to amend in the Millett case
and, thus, on December 14, 2005, Judge Robinson granted the motion to amend and the second
amended complaint was deemed tiled. In light of the overlapping claims and putative classes in
the Millett and T ownes cases, we believed it appropriate to identify these cases to the Court as
related. Defendants’ counsel previously provided notice to the parties of the related nature of
these actions.
If the Court has any questions about the foregoing, counsel for the parties will
make themselves available at the convenience of the Court to address them.
Respectfully,
William M. Lafferty (#2755) $

Case 1:04-cv-01488-JJF Document 32 Filed 12/19/2005 Page 2 of 2
Mr. Peter T. Dalleo
December l9, 2005
Page 2
cc. Ralph N. Sianni, Esquire
Brad Friedman, Esquire
Michael L. McGlamry, Esquire
Beth Parr, Esquire
Christopher J. Curtin, Esquire
Barry R. Grissom, Esquire
B. Joyce Yeager, Esquire
Bryson R. Cloon, Esquire
Michael W. Blanton, Esquire