Free Letter - District Court of Delaware - Delaware

Case 1 :04-cv—00956-GMS Document 154-2 Filed 05/01 /2006 Page 1 of 1
Burnham, Noel
From: Harvey, Carmon M.
Sent: Monday, May 01, 2006 7:02 AM
To: Burnham, Noel
Cc: Fitzgerald, Robert
Subject: Fw: Price, preliminaryjury instructions
————- Original Message --—--
From: Fitzgerald, Robert
To: Donaldson, Richard
Cc: Harvey, Carmon M.
Sent: Sun Apr 30 21:13:03 2006
Subject: FW: Price, preliminary jury instructions
Please file this e—mail as requested by Thomas Neuberger.
From: Thomas S. Neuberger, Esquire [mailto:[email protected]]
Sent: Fri 4/28/2006 9:56 AM
To: Ellis, Edward
Cc: Fitzgerald, Robert; Cheryl A. Sasadeusz, Esq.; Stephen J. Neuberger (work)
Subject: Price, preliminary jury instructions
Ed,
After I agreed to everything in your version of the disputed areas of the preliminary jury
instructions and we had a final version, you added more material. I will not agree to
the argumentative matter you added to the contentions. Nor will I agree to the material
you added before the burden of proof. As you know, that was not negotiatedand it also
deals with collateral source issues which are being separately briefed before the court.
It is inappropriate at this time in the case.
So please send the disputed draft over to the court by Monday with the two areas
highlighted.
Please also include this email which states my position.
Thank you.
Tom
**9:**%**********%****~k~k~k****~A·>l·**********
Thomas S. Neuberger, Esquire
The Neuberger Firm
Attorneys And Counsellors At Law
Two East Seventh Street, Suite 302
Wilmington, Delaware 19801-3707
Phone 302.655.0582
Fax 302.655.9329
Email: [email protected]
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