Free Letter - District Court of Delaware - Delaware

Case 1:04-cv-00910-Gl\/IS Document 214 Filed O4/12/2007 Paget 0f2
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A PROFESSIONAL ASSOCEATION
ONE: Ft’c;•:::Nr:~r Saunas
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April 12, 2007
VIA HAND DELIVERY
The Honorable Gregory Mi Sleet
United States District Court
for the District of Delaware
844 North King Street
Lock Box 19
Wilmington, Di?. i9801
Re: integrated Health Services of Cliff`l\/lanor, Inc., et al. v. TI-ICI Company
LLC, C.A. No. 04-910 QGMSQ
Dear Judge Sleet:
This firm along with the tinn of Troutman Sanders LLP are the attorneys for
plaintiffs and additional counterclaim defendant Abe Briarwood Corporation (collectively,
"Plaintiffs") in the aboveweferenced civil action. We write in furtherance to (i) the Stipztlation
and Order Extending Time For Briefing Sclteelttle on Motion by THC} Company, LLC to Enforce
the Stipzzlcttion and Order of Settlement and Disntissctl [Docket No. 212], filed by Plaintiffs on
April ll, 2007 (the "Stipulation") and (ii) Your Honors April il, 2007 "Oral Order Denying
Stipulation to Extend Tinie" with respect to the Stipulation (the "Order"), Pursuant to the
Stipulation, Plaintiffs and defendant THCX Company, LLC (“‘Defendant" and, along with
Plaintiffs, the "Parties") have agreed to extend Plaintiffs time to respond to the Motion by THC]
Company, LLC to Enforce the Stipttlotion and Order ofSettlentent and Dismissal {Docket No.
206], tiled March 28, 2007 (the "Enforcement Motion") through and including April 20, 2007.
Pursuant to Your l—Ionor’s Order, Plaintiffs have today refiled the Stipulation with
the Court in the form enclosed herewith and hereby provide this letter in accordance with Your
Honors procedures which provide that, with respect to “l\/lotions andlor Stipuiations to Extend
Time", "[t]he reason(s) for the requested relief _g_1_1§_tg be outlined in the body of the motion or
stipulation, otlterwise the parties ntust submit cr letter outlining the reosonsfor the sottglzt njiter
relief" (italics added). The basis for the extension of time agreed to by the Parties is that (i)
Plaintiffs’ client has been unavailable for a period of time since the Enforcernent Motion was
tiled and, as a result, Plaintiffs’ counsel has not yet been able to consult with our client in order
to fully formulate a response to the Enforcement Motion and (ii) certain of Plaintiffs’ counsel
were temporarily unavailable over the intervening Passover Holidays since the Enforcement
Motion was tiled, Accordingly, Plaintiffs respectfully submit that the brief consensual extension
tu Fl -3 tssesrt

Case 1:04-cv-00910-Gl\/IS Document 214 Filed O4/12/2007 Page 2 of 2
The Honorable Gregory M. Sleet
April l2, 2007
Page 2
requested in the Stipulation is reasonable and appropriate under the circumstances and hereby
request that Your Honor enter an order approving the Stipulatiorr at the Court’s earliest
convenience.
l am available should Your Honor have any questions concerning the proposed
Stipulation.
Respectfully yours,
Jason M. Madron
JMM/Ima
Enclosure
cc: Collins J. Seitz, Esq. (w/enc., via email and First Class U.S. Mail)
Davis S. Sager, Esq. (vv/enc., via e~1nail and First Class US. Mail)
Aurora Cassirer, Esq. (w/enc., via e—1nail and First Class U .S, Mail)
Lisa C. McLaughlin, Esq. (w/enc., via e-mail and First Class U.S. Mail)
Catherine P. Wells, Esq. (w/enc., via e»mail and First Class U.S. Mail)
R.LFl—3l38067-1