Free Letter - District Court of Delaware - Delaware

Case 1:04-cv-00956-GMS

Document 155

Filed 05/02/2006

Page 1 of 1

THE NEUBERGER FIRM
A TTORNEYS AND C OUNSELLORS AT L AW

TWO EAST SEVENTH STREET SUITE 302 WILMINGTON, DELAWARE 19801-3707
WWW.N EUBERGERL AW.COM EMAIL: I NFO@N EUBERGERL AW.COM

T HOMAS S . N EUBERGER, ESQUIRE S TEPHEN J . N EUBERGER, ESQUIRE
May 2, 2006 The Honorable Gregory M. Sleet United States District Court District of Delaware 844 King Street Wilmington, DE 19801 RE: Price, et al. v. Chaffinch, et al., C.A. No. 04-956-GMS Comments on Proposed Voir Dire

PHONE: (302) 655-0582 FAX: (302) 655-9329

Via CM/ECF Filing

Dear Judge Sleet: This letter is written in response to Ms. April Walker's communication of last Thursday, requesting comment on the proposed voir dire questions. Last Wednesday, plaintiffs submitted a letter to the Court (D.I. 145) addressing this issue. Plaintiffs' letter and the Court's communication may have crossed in transit. Relatedly, plaintiffs intend to call retired Capt. Gregory A. Warren as a witness. As occurred at his deposition, it is probable that defendants intend to impeach this witness with the fact that he had previously filed a lawsuit against Governor Minner in 2003. (See Warren Depo. at 23-26,192-95). Plaintiffs respectfully submit that this also weighs in favor of a voir dire question addressing the Governor. Respectfully submitted, /s/ Stephen J. Neuberger Attorney for Plaintiffs cc: Thomas S. Neuberger, Esq. (via CM/ECF) Martin D. Haverly, Esq. (via CM/ECF) Richard M. Donaldson (via CM/ECF)

FTU \ Letters \ Sleet.10