Free Letter - District Court of Delaware - Delaware

Case 1:04-cv-00389-***-MPT
800 N. King Street Suite 300 Wilmington, DE 19801 Telephone: 302-426-1900 Facsimile: 302-426-9947

Document 33

Filed 08/08/2005

Page 1 of 1

Marla Rosoff Eskin · [email protected]

Campbell & Levine, LLC
Attorneys at Law

August 8, 2005 The Honorable Mary Pat Thynge United States District Court for the District of Delaware J. Caleb Boggs Federal Building 844 North King Street, Room 6100 Lockbox 8 Wilmington, DE 19801 RE: PSA Inc. v. Dean Hollis Velazco, et al. ­ C.A. No. 04-0389 ­ KAJ Dear Magistrate Thynge: I am in receipt of the letter dated August 5, 2005 from PSA to Your Honor regarding a discovery dispute in the above-captioned matter. As seems to be the pattern in this case, PSA has ignored the rules. Judge Jordon's procedures for discovery disputes, as well as the procedure set forth in the Scheduling Order signed on February 4, 2005 in this case require that when there is a discovery dispute, the first step is for counsel to contact Judge Jordon's chambers to schedule a telephone conference. The procedure set forth in the Scheduling Order was circumvented. As the proper procedures were not followed, I request that the August 5, 2005 letter from PSA not be considered. Should Your Honor desire a formal response to the substance of the letter from PSA, please advise and I will respond. I would note that the discovery dispute, in large part, is related to PSA's Motion to Amend the Complaint, which is now pending before Judge Jordon. Very truly yours, /S/ Marla Rosoff Eskin Marla Rosoff Eskin cc: The Honorable Kent A. Jordon (hand delivery) Jonathan W. Jordan, Esq. (regular mail and electronic delivery) Sean Beach, Esq. (hand delivery)

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Wilmington, Delaware · Pittsburgh, Pennsylvania