Free Letter - District Court of Delaware - Delaware

Case 1 :04-cv—00877-GIVIS Document 34 . Filed 08/24/2005 Page 1 of 1
SEITZ, VAN Ocrnoe Bt GREEN, RA.
ATTORNEYS AND COUNSELLDRS AT LAW
zzz DELAWARE AVENUE. sum: woo
nosr cme: sox ee
WILMINGTON, DELAWARE mm
BERNARD A. vAN oGrROP <302> 86¤<>600
°°°"°‘ "· $‘"’· "' writers Direct mai; (302) sas-7607 FAX; ‘°°*’ °°°°°°°
;f'f,fg‘,L‘”‘ Writer's E-Mail Address: [email protected]
p,(-mgm p_ MOGONH; www.lawyers.com/svglaw
KEVIN A. GUERKE
August 24, 2005
Via E-F ile and Hand Delivery
The Honorable Gregory M. Sleet
United States District Court
844 North King Street, Lock Box 19
Wilmington, DE 19801
RE: Hartz v. Fager, Civil Action No. 04-877 (GMS)
Dear Judge Sleet:
I am local counsel for the Plaintiffs in the above matter. Pursuant to the Court's March
14, 2005 Scheduling Order, Plaintiffs' expert discovery deadline is September 1, 2005,
Defendant's expert discovery deadline is October 1, 2005, and all discovery shall be completed
by November 1, 2005. I am writing to request a 30-day extension of these deadlines and enclose
for the Court's approval a Stipulation in this regard signed by all counsel.
I make this request for the following reason: This case is scheduled for a mediation
conference with Magistrate Thynge on September 1, 2005. In order to meet the September lst
expert deadline, Plaintiffs would have to incur additional costs to obtain fmal reports from their
treating doctors. By extending the expert deadline for 30 days (to October l, 2005), Plaintiffs
would be able to delay these additional costs and increase the chances of settlement.
Thank you for your consideration of this matter.
Respectfully,
Kevin A. Guerke, Esq. (DE #4096)
KAG:cde
Enclosure
cc: Richard M. Wiener, Esq.
Michael A. Pedicone, Esq.