Free Proposed Order - District Court of Delaware - Delaware

Case 1:04-cv-01488-JJF Document 28-2 Filed 11/17/2005 Page 1 of 1
MORRIS, NICHOLS, ARSHT & TUNNELL
1201 NORTH MARKET STREET
P.O. Box 1347
WILMINGTON, DELAWARE 19899-1347
302 658 9200
WILLIAM LAFFERTY FAX
302 575 7341
302 425 4679 FAX November 17, 2005
[email protected]
VIA E-FILING
The Honorable Joseph J. Faman
United States District Court
District of Delaware
844 King Street
Wilmington, Delaware 19801
Re: Townes v. TransUni0n LLC, et al, C.A. N0. 04-1488 JJF
Dear Judge Farnan:
Pursuant to Your Honor’s November 2, 2005 letter to counsel, enclosed is a copy
of the parties’ Proposed Joint Rule 16 Scheduling Order, all terms of which have been agreed to
by counsel. However, the parties wish to note and explain the proposed schedule with regard to
summary judgment motions, which we recognize represents a departure from Your Honor’s
Memorandum Order regarding the briefing and submission of such motions. The parties are in
agreement in their belief that there may be significant issues in this case that may be determined
as a matter of law. For this reason, the parties have proposed a schedule which combines
substantive briefing on summary judgment motions with the exchange of Statements and
Counter-Statements of material facts in order to better define the overall schedule for this
litigation. Of course, if Your Honor has any concems or 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)
cc. Clerk, U.S. District Court
Ralph N. Sianni, Esquire
Brad Friedman, Esquire
Michael L. McGla1nry, Esquire
Beth Parr, Esquire