Free Letter - District Court of Delaware - Delaware

Case 1 :04-cv-00913-GIVIS Document 45 Filed O3/O9/2006 Page 1 of 1
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Qlaines E. Liguori
Gregory A. Morris
Laura A. Yiengst
March 9, 2006
The Honorable Kent A. Jordan
District Court for District of Delaware
844 N. King Street, Lock Box 10
Wilmington, DE 19801
RE: CROTHER ET AL. V. DEWEY BEACH ET AL.
CA N 0.:04-913-KAJ
Dear Judge Jordan,
The undersigned counsel represents the Plaintiffs Theresa Crother, George Green, Gregory A.
Parise and Michael Whetstone. The Town of Dewey Beach, Chief of Police Samuel Mackert, Patrolman
Zachary Pettyjohn, and Patrolman John Wheatey are represented by Kevin Connors, Esquire.
The current scheduling order has a trial date set for November 20, 2006. The parties are jointly
requesting that the scheduling order be amended to allow additional discovery and to push back the
Dispositive Motion cutoff date for April 30, 2006. The request is being made because the patties have
been extending significant efforts to resolve the cases. The parties still need to complete approximately ‘
ten (10) depositions and propose that the new discovery cut off be April 30, 2006 and the Dispositive
Motion deadline he set for May 30, 2006. All parties are in agreement with this request and do not wish
ter the Trial date to he rescheduled unless the Court feels that the trial date can not be kept because of the
above—referenced changes to the scheduling order. The Plaintiffs request that the Motion for Summary
ludgnient filed by Defendants be held in aberrance until the discovery has been completed.
if you have any questions concerning this matter, please do not hesitate to contact counsel for
Plaintiffs or Defendants
Very truly yours,
LIGUORI, MORRIS & YIENGST
/s/ James E. Liguori
JAMES E. LIGUORI, ESQUIRE
46 The Green
Dover, DE 19901
(302) 678—99OO
Attorney for Plaintiff
TEL/tlb ‘
cc. Kevin Connors, Esq.