Free Letter - District Court of Delaware - Delaware

Case 1 :04-cv-01482-GMS Document 82 Filed 05/26/2005 Page 1 of 2
F I N G IC R & S LA N I N A, r,1,(j David L. riiigei, Residcm, wiimiiigmii ornce;
One Commerce Center, 1201 Or St., S `t 725
A A ¤ <> A N A A A A or A A W Wilmington, D.i;‘.‘$§f. 68813 ii.
Ph: (302) 884-6766 1 Fax: (302) 984-1294
E—mail: [email protected]
www.delawgroup.com
May 26, 2005
Via CM/ECF
The Hon. Gregory M. Sleet
U.S. District Court for the District of Delaware
844 N. King St., Lock Box 19
Wilmington, DE 19801
Re: Davis International, LLC, et al. v. New Start Group, Inc., et aL
D. Del., C.A. Nos. 1482 & 1483 GMS
Dear Judge Sleet:
Pursuant to the Court’s request, this letter sets forth the reason that plaintiffs (with
defendants’ concurrence) have requested an extension of time for filing their Answering Brief in
Opposition to Plaintiffs’ Motion to Dismiss the Complaint Pursuant to the Doctrine of Direct
Estoppel and to Enj oin Plaintiffs from Re-Filing This Action.
The reason that plaintiffs have asked for a one day extension is that my co-counsel,
Mr. Marks, requested the original May 24 filing date based on his review of his office calendar,
which permitted him to work with his team of attorneys over the weekend of May 17 to finalize the
filing. However, he was unaware from his office calendar that he had a personal family obligation,
i.e., the bar-mitzvah of his nephew in Atlanta, which required his presence from Thursday, May 16
through Sunday, May 19.
Plaintiffs have thus asked for an extension from Friday to the next business day,
Tuesday, May 21 so that they may finalize the filing over the weekend.
As always, l am available at the convenience of the Court to answer any questions
Your Honor may have.
Respectfully,

1
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David n {
(DE Bar ID #255 .

Case 1:04-cv-01482—G|\/IS Document 82 Filed 05/26/2005 Page 2 of 2
cc: Clerk of the Court (via CM./ECP)
Collins J. Seitz, Jr., Esq. (via CM/ECF)
Richard l.G. Jones, Esq. (via CM/ECF)
William M. Lafferty, Esq. (via CM/ECF)
Charles M. Oberly, III (via CM/ECF)