Free Letter - District Court of Delaware - Delaware

Case 1:04-cv-01026-KAJ Document 48-2 Filed O3/28/2006 Page 1 of 4
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Messe? Case 1:04-cv-01026-KAJ Document 48-2 Filed O3/28/2006 Page 2 efw 1 Of 3
Ashley Stitzer
From: Frederick B. Rosner [frosner@jshIlp—de.com]
Sent: Monday, February 06, 2006 11:55 Al\/I
To: Ashley Stltzer
Subject: RE: NR v. Bobcat
Agreed, but l may ask for a few more days on responses to discovery if that is OK. l'1n transitioning iirms.
Frederick B. Rosner, Esq.
Jaspan Schlesinger Hoffman LLP
913 Market Street, 12th Floor
Wilmington, DE 19801
Telephone: 302-351-8000/8005
Facsimile: 302-351-8010
Mobile: 302-588-4253
E-mail: [email protected]].lD:[email protected]
From: Ashley Stitzer [mailto:[email protected]]
Sent: Monday, February 06, 2006 11:45 AM
To: Frederick B. Rosner
Subject: RE: NR v. Bobcat
Importance: High
Fred:
l think we need more time for expert discovery. At your earliest convenience, please advise whether
you agree with the following dates:
Fact Discovery Deadline — 4/20
Expert Disclosures — 4/27
Expert Rebuttal Disclosures 5/1 l.
Expert Discovery Completed — 6/1
Also, l wanted to confirm that the deadline for the defendant to respond to the outstanding written
discovery requests is 30 days from the hearing or March 3. Thanks, Ashley
Ashley B. Stitzer, Esq.
The Bayard Firm
222 Delaware Avenue, 9th Floor
Wilmington, Delaware 19801
Main: (302) 655-5000
Direct: (302) 429-4242
Fax: (302) 658-6395
Website: WWVW~ilL?£i}’§1IClllIl11-QQ131
-———— Original Message ———-—
From: Frederick B. Rosner [mailto:frosner@jshIlp—de.com]
3/28/2006

Meeeege Case 1 :04-cv-01026-KAJ Document 48-2 Frreer oe/28/2006 Page a eeeree 2 ef 3
Sent: Monday, February 06, 2006 10:39 AM
T0: Ashley Stltzer
Subject: RE: NR v. Bobcat
Ashley, let me know ifthese dates work for you. Pls disregard the cross out l made in paragraph 6, Thanks.
Frederick B. Rosner, Esq.
Jaspan Schlesinger Hoffman LLP
913 Market Street, 12th Floor
Wilmington, DE 19801
Telephone: 302-351-8000/8005
Facsimile: 302-351-8010
Mobile: 302-588-4253
E—mai1:
From: Ashley Stitzer [mailto:[email protected]]
Sent: Wednesday, February 01, 2006 12:16 PM
To: Frederick B. Rosner
Subject: NR v. Bobcat
Fred:
In follow up to the parties agreement at the hearing on this date, attached please find in word format the
scheduling order previously entered by the Court. The attached order is revised to make it specific to
Bobcat and to include the dates entered by the Court in the original order. Please provide suggested
dates for paragraphs 1(c) and (d) and return the same to me for review and comment. The mediation
dates are June 5, 7-9 and 12.
In addition, attached please find in word format the Trustee's written discovery requests. Thanks,
Ashley
Ashley B. Stitzer, Esq.
The Bayard Firm
222 Delaware Avenue, 9th Floor
Wilmington, Delaware 19801
Main: (302) 655-5000
Direct: (302) 429-4242
Fax: (302) 658-6395
Website: www.bay.ar<1,1i1·.1n.eo,1n
=00 --——-————--—--—----——----—--—-—--—-
IRS Circular 230 DISCLOSURE:
Notice regarding federal tax matters: Internal Revenue Service Circular 230 requires us to state herein
that any federal tax advice set forth in this communication (1) is not intended or written to be used, and
cannot be used, for the purpose of avoiding penalties that may be imposed by federal tax laws, and (2)
cannot be used in promoting, marketing, or recommending to another person any transaction or matter
addressed herein.
3/28/2006

Message Case 1:04-cv-01026-KAJ Document 48-2 Filed O3/28/2006 Page 4 o?¤H€ 3 OH
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IRS Circular 230 DISCLOSURE:
Notice regarding federal tax matters: Internal Revenue Service Circular 230 requires us to state herein
that any federal tax advice set forth in this communication (l) is not intended or written to be used, and
cannot be used, for the purpose of avoiding penalties that may be imposed by federal tax laws, and (2)
cannot be used in promoting, marketing, or recommending to another person any transaction or matter
addressed herein. ’
This message is sent by a law firm and may contain information that is privileged or confidential. If you
received this transmission in error, please notify the sender by reply e—mail and delete the message and
any attachments.
3/28/2006