Free Letter - District Court of Delaware - Delaware

Case 1 :04-cv-01394-GIVIS Document 45 Filed 03/10/2005 Page 1 of 1
ATTORNEYS AND COUNSELLORS AT LAW
Two EAST SEVENTH STREET
SUITE 302
WILMINGTON, DELAWARE 19801-3707
WWVV.NEUBERGERLAW.COM
EMAIL! [email protected]
THOMAS S. NEUBERGER, ESQUIRE PHoNE: (302) 655-0582
STEPHEN J. NEUBERGER, ESQUIRE FAX; (302) 655-9329
March 10, 2005 Via CM/ECF Filing
The Honorable Gregory M. Sleet
United States District Court
District of Delaware
844 King Street
Wilmington, DE 19801
RE: Conley v. Chaffinch, et al., Civil Action N0. 04-1394-GMS
Dear Judge Sleet:
Today plaintiff has filed a Proposed Rule 16 Scheduling Order and a Status Report for
use in our Rule l6(b) conference scheduled for next Thursday, March 17, 2005.
On Tuesday, March 8‘h, I contacted your Case Manager Ms. McDavid and inquired as to
whether the March 17*** conference was a Fed.R.Civ.P. l6(a) or l6(b) conference. Upon leaming
that it was a Rule l6(b) conference, I immediately prepared the appropriate submissions and sent
them to defense counsel along with a request that we confer about them and also fulfill our Rule
26(f) obligations.
In response defense counsel indicated that he was too busy to review the documents or to
confer, but that he hoped to find time on Friday to call plaintiff s counsel.
Plaintiff will continue to work diligently to meet and confer with defendants in
preparation for next week’s Rule 16 conference. If any changes are made to the above referenced
submissions, plaintiff will file them with the Court.
Respectfully submitted,
/s/ Stephen J . Neuberger
cc: Ralph K. Durstein, Esq. (Via CM/ECF)
Conley \Letters \ Sleet.04 ·