Free Status Report - District Court of Delaware - Delaware

Case 1:04-cv-01462-KAJ

Document 25

Filed 05/24/2005

Page 1 of 2

MARKS, O'NEILL, O'BRIEN & COURTNEY, P.C.
PHILADELPHIA OFFICE SUITE 1200 1880 JOHN F. KENNEDY BLVD. PHILADELPHIA, PA 19103 (215) 564-6688 FAX (215) 564-2526 NEW YORK OFFICE 530 SAW MILL RIVER ROAD ELMSFORD, NY 10523 (914) 345-3701 FAX (914) 345-3743 MARYLAND OFFICE THE BONAPARTE BUILDING 8 EAST MULBERRY STREET BALTIMORE, MD 21202 (410) 385-8335 FAX (410) 385-5883

ATTORNEYS AT LAW SUITE 800 913 N MARKET STREET WILMINGTON, DE 19801 -------- (302) 658-6538 FAX (302) 658-6537

NEW JERSEY OFFICE SUITE 300, COOPER RIVER WEST 6981 NORTH PARK DRIVE PENNSAUKEN, NJ 08109 (856) 663-4300 FAX (856) 663-4439 PITTSBURGH OFFICE GULF TOWER, SUITE 3200 707 GRANT STREET PITTSBURGH, PA 15219 (412) 391-6171 FAX (412) 391-8804 BUCKS COUNTY OFFICE SUITE 106 10 SOUTH CLINTON STREET DOYLESTOWN, PA 18901 (267) 880-3696 FAX (267) 880-0545 Norman H. Brooks, Jr.

May 24, 2005 The Honorable Kent A. Jordan United States District Court District of Delaware 844 North King Street Lock Box 10 Wilmington, DE 19801 VIA HAND DELIVERY & Electronic Filing Re: Baylis v. Red Lion Group, Inc. C.A. No. 04-1462 KAJ Our File No. 794-73782

Interim Status Report
Dear Judge Jordan: As per your Honor's Scheduling Order of February 15, 2005, please accept this as Defendant's Interim Status Report. As indicated by Plaintiff's report of May 23, discovery is proceeding in this matter and it is anticipated by Defendant that discovery will be completed within the period prescribed in the Court's Scheduling Order. While Plaintiff was delayed in the identification of her medical expert, Dr. David Sowa, counsel was able to amicably resolve the situation and Defendant does not object to Dr. Sowa's identification. It is my understanding that Plaintiff's expert is currently preparing his report, and upon its completion a copy will be provided
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Case 1:04-cv-01462-KAJ
MARKS, O'NEILL, O'BRIEN & COURTNEY, P.C.

Document 25

Filed 05/24/2005

Page 2 of 2

The Honorable Kent A. Jordan page 2

by Plaintiff's counsel. Concerning Defendant's identification of experts, Defendant anticipates identification of its expert will occur by June 5, 2005 as per the Scheduling Order. Defendant has scheduled and noticed the depositions of John Peters and Jerry McCarthy for June 29, 2005, in advance of the July 5, 2005 discovery completion deadline. Further, records from Plaintiff's medical treatment providers and workers compensation provider were subpoenaed so as to be received prior to the discovery deadline. Plaintiff's counsel has requested copies of these records be provided to him. I await the May 31, 2005 Status Conference with the Court. Respectfully Submitted, /s/ Norman H. Brooks, Jr. (No. 2568) NORMAN H. BROOKS, JR. NHB/dpd cc: Bayard Marin, Esq.

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