Case 1:04-cv-01384-GMS
Document 25
Filed 10/31/2005
Page 1 of 1
800 N. King Street Suite 300 Wilmington, DE 19801 Telephone: 302-426-1900 Facsimile: 302-426-9947
Mark Hurford · [email protected]
Campbell & Levine, LLC
Attorneys at Law
October 31, 2005 VIA ELECTRONIC FILING Marie McDonald, Case Manager United States District Court for the District of Delaware J. Caleb Boggs Federal Building 844 King Street Room 4324, Lockbox 19 Wilmington, DE 19801 Re: United States f/b/o Earth Savers, Inc. v. PBM Construction Group, Inc. and Capitol Indemnity Corporation; CA No. 04-1384 (GMS)
Dear Ms. McDonald: Please accept this correspondence as the joint status report on behalf of Earth Savers, Inc. ("Earth Savers") and Capitol Indemnity Corporation ("Capitol"), in response to your letter of October 13, 2005. Please be advised that a Stipulation of Dismissal has been executed between Earth Savers and Capitol, a copy of which has been filed this afternoon. The only remaining issue is for Earth Savers to file the appropriate papers to obtain a judgment against PBM Construction Group, Inc., who has already been defaulted for failure to appear. As the Complaint sought a sum certain, this can be completed this week. If you have any additional questions or comments, we remain available.
Respectfully submitted,
Respectfully submitted,
/s/Mark T. Hurford Mark T. Hurford, Esq. Campbell & Levine, LLC
/s/Victoria Petrone Victoria Petrone, Esq. Tighe, Cottrell & Logan, PA
{D0050583:1 }
Wilmington, Delaware · Pittsburgh, Pennsylvania