Free Letter - District Court of Delaware - Delaware

Case 1 :04-cv—01482-GIVIS Document 123 Filed 07/11/2008 Page 1 of 2
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July ll, 2008
VIA ELECTRONIC FILING `
Honorable Gregory M. Sleet
U.S. District Court for the
District of Delaware
844 North King Street
Lock Box l8
Wilmington, DE 19801
Re: Davis International, LLC v. New Start Group Corp., et al.
C.A. No. 04-ev-1482 (GMS)
Dear Chief Judge Sleet:
We write on behalf of defendant Oleg Deripaska in response to the July 7, 2008 letter
sent to the Court on behalf of plaintiffs. Plaintiffs request a "stay of the Court’s decision on the
pending anti-suit motion until the Davis Plaintiffs have had time to study the decision and
formulate their position on the impact of this decision on the pending litigation?
i The motion pending before the Court for decision was brought by the ten defendants in
this case, as to whom all p1aintiffs’ ciaims have been dismissed and affirmed on appeal. The
English Court decision attached to counsel’s letter is from an unrelated dispute between only two
of the ten defendants. Plaintiffs do not say, and cannot sy, that this decision mentions the
plaintiffs in this action or the subject of the pending motion »- which is laintiffs’ U.S. litigation
misconduct. indeed, plaintiffs do not say, and cannot say, that the decision mentions the subject
of plaintiffs dismissed claims in this action — the Russian company known by the acronym
Q GOK, or the vanadium industry in which it is said to be engaged. Eight of the ten moving
E defendants are not parties to the English proceedings.
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Case 1 :04-cv—01482-GIVIS Document 123 Filed 07/11/2008 Page 2 of 2
The Honorable Gregory M. Sleet
July 11, 2008
Rage 2 of 2
If the Court believes it would be helpful for defendants to address plair1tiffs’ letter in
detail, and the many inaccuracies contained in the letter, we will do so in a manner and on a
schedule that the Court deems appropriate.
Respectfully,
Collins J. $@2, Jr. \q
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cc: Clerk of the Court (via CM/ECP)
Bavid L. Finger, Esq. (via CM/ECP)
Richard I. G. Jones, Esq. (via CM/ECF)
William M. Lafferty, Esq. (via CM/ECP)
Charles M. Oberly, IH, Esq. (via CM/ECP)
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