Free Letter - District Court of Delaware - Delaware

Case 1 :04-cv-00360-JJF Document 63 Filed O9/27/2005 Page 1 of 2
Monnrs, Nrcrrots, Ansar & Tuniinirn
l20l. Nonrir Manner Srnnistr
P.O. Box 1347
Wrrmrncron, Demwnnn ll-:l899——i3é7
302 658 9200
302 658 3989 Fax
Mnstrnrsman Nonnma
302 575 rzrs
sez as 3011 rn September 27, 2005
¥§BOfEirk&@¥HBB{.EGH1
BY ELECTRONIC FILING
The Honorable Joseph .l. Farnan, Jr.
United States District Court
844 N. King Street
Wilmington, DE 19801
RE: Trilegiant Loyalty Solutions, Inc. v. Maritz, Inc.
Civil Action No. 04-360-JJ]?
Dear Judge Farnan:
On behalf of both Plaintiff Trilegiant Loyalty Solutions, Inc. and Defendant Maritz,
Inc., we submit the enclosed stipulation and proposed order to amend the March 2, 2005, Scheduling
Order in the above case.
The parties have made substantial progress in discovery, including completing
voluminous document productions, and will take fact depositions over the next few months. As the
Court will recall, the date for completion of document production was extended by 10 weeks after
the date set in the original March 2 Scheduling Order, but none ofthe other dates were adjusted at
that time. The parties have conferred extensively as to the appropriate schedule for completing
discovery and believe that the proposed amended scheduling order reflects a practical schedule for
moving this case expeditiously toward trial. Therefore, the parties jointly request that the Court
adopt the proposed amended scheduling order and set a new trial date for October 2006, as the
Conrt’s schedule permits. We would request that the trial date not be set for the first week of
October 2006 to avoid conflicts with counsel’s observance of Yom Kippur. The parties also propose
that the Markrnan hearing and pretrial conference be set for June and September 2006, respectively,
on dates that are convenient for the Court.
Respectfully,
/s/ Maryellen Noreika (#3208)
Maryellen Noreika

Case 1:04-cv-00360-JJF Document 63 Filed O9/27/2005 Page 2 of 2
The Honorable Joseph J. Faman, Jr.
September 27, 2005
Page 2
MN/bls
cc: Peter T. Dalleo, Clerk (By Hand)
Patricia Smlnk Rogowski, Esquire (By Hand)
J. Bennett Clark, Esquire (By Fax)
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Case 1:04-cv-00360-JJF

Document 63

Filed 09/27/2005

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Case 1:04-cv-00360-JJF

Document 63

Filed 09/27/2005

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