Free Letter - District Court of Delaware - Delaware

Case 1:04-cv-01452-JJF Document 54 Filed O3/22/2006 Page 1 of 1
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March 22, 2006 I
BY ELECTRONIC FILING AND HAND DELIVERY
The Honorable Joseph J. Farnan, Jr.
United States District Couit for
the District of Delaware
844 King Street
Wilmington, Delaware 1980l
Re: E.I. DuPont de Nemours v. Great Lakes Chemicals,
C.A. No. 04-1452-.JJF
Dear Judge Farnan:
Pursuant to District of Delaware Local Rule 7.1.4, defendant Great Lakes
Chemicals (“Great Lakes") respectfu.1lly requests that Your Honor hear oral argument on Great
Lakes’ Motion for Leave to File an Early Summary Judgment Motion and for a Stay of
Discovery During Consideration Thereof (the "Motion”) (D.I. 46). With the filing of Great
Lakes’ Reply Brief on March 20, 2006, the parties have concluded briefing on the Motion.
Great Lal insofar as Great Lakes was ultimately able to submit its reply brief on the day to which defendant
El. DuPont de Nemours consented, which was also the day Great Lakes understood its brief was
due.
Thank you for your consideration. Counsel remains available should Your Honor
have any questions.
Respectfully, V
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Al\/{Stains
cc: Clerk ofthe Court (by electronic tiling)
Richard L. Horwitz, Esquire (by electronic filing and hand delivery)
David E. Moore, Esquire (by electronic tiling and hand delivery)
Bruce D. DeRenzi, Esquire (by electronic filing and facsimile)
John T. Clallaglier, Esquire (by electronic filing and facsimile)
Frederick Li Cottrell, III, Esquire
air:-2.991915-1