Free Motion to Enjoin - District Court of Delaware - Delaware

Case 1 :04-cv-00871-SLR Document 13-2 Filed 07/15/2005 Page 1 of 2
IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF DELAWARE
RICHARD R. CEPHAS,
Plaintiff, Civil Action No. O4-871-SLR
PHILADELPHIA MARINE TRADE
ASSOCIATION, :
and
INTERNATIONAL LONGSHOREMAN’S
ASSOCLATION, :
Defendants.
DEFENDANT’S STATEMENT OF EFFORT TO REACH AN AGREEMENT
PURSUANT TO LOCAL RULE OF CIVIL PRACTICE AND PROCEDURE 7.1.1
Pursuant to Local Rule of Civil Practice and Procedure 7.1.1, Defendant
Philadelphia Marine Trade Association ("PMTA") contacted Plaintiff Richard Cephas, who is
appearing in this matter pro se, to confer regarding Defendant PMTA’s Motion to Join an
Additional Defendant. Plaintiff was contacted on or about July 1, 2005 wherein the parties
discussed the instant Motion in an effort to reach an agreement on Joining the Container Royalty
Fund as an additional Defendant. At the conclusion of the discussion, Plaintiff informed
Defendant that he would get back to Defendant after the holiday weekend. To date, Plaintiff has
not contacted Defendant to discuss the instant Motion.

Case 1 :04-cv-00871-SLB Document 13-2 Filed 07/15/2005 Page 2 of 2
Defendant PMTA also attempted to contact counsel for Defendant International
Longshoreman’s Association ("ILA") pursuant to Local Rule of Civil Practice and Procedure
7.1.1 to reach an agreement on joining the Container Royalty Fund as an additional Defendant.
Counsel for Defendant ILA has not responded to Defendant PMTA’s efforts to discuss the
instant Motion.
Respectfully Submitted,
\;
Arr : Nee ,112. (# 2164)
JAME g LIVAN, R. (# 2266)
Klett Rooney Lieber & Schorling, P.C.
The Brandywine Building
1000 West Street, Suite 1410
Wilmington, Delaware 19801
(302) 552-4200
Attorneys for Defendant
Philadelphia Marine Trade Association
July 15, 2005
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