Free Status Report - District Court of Delaware - Delaware

Case 1 :04-cv-0141 1-KAJ Document 25 Filed 09/06/2005 Page 1 of 2
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September 6, 2005 I
The Honorable Kent Jordan
United States District Court
District of Delaware
J. Caleb Boggs Federal Building
844 North King Street, Room 6325
Lock Box 10
Wilmington, DE 19801
RE: Joyce Comet! v. Nathaniel Edwards, Jr. and Federal Express
Case N0. 04-1411
Our File No. 300,626
Dear Judge Jordan:
Kindly accept the following as an Interim Status Report in the above referenced matter.
Despite the efforts, there have been many scheduling conflicts. The plaintiff has not appeared
for her deposition on two occasions despite adequate notice. We have scheduled her deposition
again for September 9, 2005. Additionally, we received no expert reports from plaintiff. Her
answers to discovery have not clearly delineated the damages she is claiming occurred as a result
of this accident despite our attempts requesting clarification. In a recent telephone discussion,
plaintiffs counsel advised us ofthe claims he believed were related to the motor vehicle
accident. However, in an attempt to move the case forward, we scheduled the plaintiff to be
evaluated by a neurosurgeon. Unfortunately, plaintiff failed to appear for this evaluation despite
adequate notice. We have also provided plaintiff with dates to be evaluated by a vocational
expert. Our expert is willing to evaluate the plaintiffat the plaintiff’s counsel’s office.
Per our discussion with your chambers and given the scheduling difficulties, we request a
sixty day extension ofthe discovery deadlines. This extension shall not affect the trial schedule.
I [98704 v.l

Case 1:04-cv-01411-KAJ Document 25 Filed 09/06/2005 Page 2 of 2
The Honorable Kent Jordan
September 6, 2005
Page 2
It is our understanding that the above contlicts shall be discussed during the telephonic
status conference scheduled for September 7, 2005, at 4:30 p.m.
8
Very truly yours,
RAWLE 8.2 HENDERSON LLP
By: /s/ Delia A. C/ark
Dawn L. Jennings
Delia Clark
DLI/’
cc: Thomas Sacchetta, Esquire
Timothy Rafferty, Esquire
1198704 v.]