Free MEMORANDUM in Support - District Court of Delaware - Delaware

_' Case 1 :04-ov—01339-SIR Document 41 -9 Filed 06/03&’2005 Page 1 of 2
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EXHIBIT H -
Monnrs, Niorrors, Ansrrr & Trrzsrnnrr.
l20l Norm Manu: Srxzsr
P.O. Box IH?
Wiutmcron, Dzuwnu 19899-1347
302 658 9200
302 558 3989 Fax
S. Main.: Hunu
ZZ? ZZ? Eli; s. Ssstmiwt 13, 2004
sbm·d@mnnt-mm
By Fax and Federal Express
Isaac M. Neuberger, Esquire
Thomas M. Wood, IV, Esquire
Neubergcr, Quinn, Gielen, Rubin & Gibber, FKA.
One South Street, 27th Floor
Baltimore, Maryland 21202
Rc: Shamrock Holdings of California, Inc., et al.
v. Avie Arenson, et al.; Civil Action No. 692-N
Dear Messrs. Neuberger and Wood:
Enclosed please End a copy of the complaint in the above-referenced action,
which was tiled today in thc Delaware Chancery Court. My Erm is c¤—¢¤¤mS¤l for the plaintiffs
Because Ms. Jarvis is at present out of the country, she asked that I convey the
following to you.
1. The cormnencement of this action reflects no diminution in plaintiffs}
desire to engage in the previously discussed mediation with your clients. However, it has been
more than two weeks since plaintiffs Erst proposed the mediation, and you have yet to agree to
it. Consequently, plaintiffs thought it prudent to pursue the mediation in the context of a pending
action.
2. Plaintiffs recognize that the upcoming holidays will affect your and your
c1ients’ availability over the next month or so, and we are of course prepared to accommodate
your needs in terms of time to respond to the complaint.
3. Please let us know as soon as possible whether you will accept service of
the complaint on behalf of your clients. We will be happy to prepare a stipulation addressing
service as well as additional time for your responding papers. `

._ Case 1 :04-cv-01339-Sif i Document 41 -9 Filed 06/O3/2005 Page 2 012
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Isaac M. Neuberger, Esquire
Thomas M. Wood, IV, Esquire
September 13, 2004
Page 2
Ms- Jarvis will be back in her office ou Wednesday, September 15, but in the
meantime, please feel Bee to contact mc.
Very guly yours,
;%@
S. Mark Hurd ·--—
SMI-I/dmd
Enclosure