Free Letter - District Court of Delaware - Delaware

` Case 1 :04-cv-00910-GIVIS Document 136 Filed 03/13/2006 Page 1 of 2
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March 13, 2006
Via E·Fiiing
Hon. Gregory Nl. Sieet, U.S.D.J.
United States District Court
J. Caleb Boggs Federai Building
844 N. King Street
Room 324, Lockbcx 19
Wiirnington, DE 19801
REE: Integrated Health Services of Ciiff Nlanorv. THCI: 04»·9t0 (GMS)
Dear Judge Sieet:
We are of counsei to piaintiffs and the additional counterclaim defendant, as weil
as to two of three nonparties to whom defendant has addressed subpoenas. Our
Delaware co·coonsei is this day tiling a motion seeking to dismiss counterciaims
contained in defendants Third Amended Counterciaims, and also for a protective order
to quash the subpoenas. We have joined the second branch not oniy because it is
related to the tirst branch, but because, pursuant to a stipulation which Your Honor so-
ordered, piaintiffs and the witnesses have until today to make such a motion.
We are not unrnindful of your procedures for a conference regarding discovery
disputes, and are prepared to hold one now, even though the motion, for the reasons
stated above, has already been made. However, Your Honor has advised that the
decision on the related appear is imminent, andthat you wanted a conference call after
that decision is handed down. it would therefore appear practicai to address the
discovery questions in that conference call, particularly since the decision, whichever
way it goes, is likeiy to impact on the discovery questions.
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Rrcrrmown ·· Tvsows Coen:-za. · VIRGINIA Bence. - Watsrsrworow. D.C.
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Case 1 :04-cv-00910-GIVIS Document 136 Filed 03/13/2006 Page 2 of 2
TROUTMAN SANDERS LLP
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Hen. Gregory M. Sieet, U.S.D.J.
March 13, 2006
Page 2
Of course, ifYour Honor would prefer e discovery conference before deciding the
appeal, we stand ready to proceed on that basis.
Respec
Amos Alter
Cc (via E»i\/iail):
Collins J. Seitz, Esq.
Connolly Bove Lode & Hutz LLP
David Sager, Esq.
Piney l-iardin LLP
Richard W. Riley, Esq.
Duane Morris LLP
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