Free Reply Brief - District Court of Delaware - Delaware

Case 1:04-cv-00175-JJF Document 170-4 Filed 08/25/2008 Page 1 of 2
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Case 1:04-cv-00175-JJF Document 170-4 Filed 08/25/2008 Page 2 of 2
ly CONNOLLY BOVE LODGE 8e HUTZ LLP _
A ATTORNEYS AT LAW
WILMINGTON, DE
The Nemours Building
Brian R. Lemon 1007 North Orange St.
tsl. (sua) 888-6319 20. B¤>< 2207
FAX (3¤2>65B·6246 wiimingm, oe 19899
E’!£i.bi!§'&3f..‘?:§§ZEi°3'f%.. 1111-= (392) 658 9141
FAX: (302) 658 5614
Junlg 26, WEB: www.cblh.com
VIA FACSIMILE AND U.S. MAIL ‘
Daniel A. Griffith, Esquire
Whiteford Taylor & Preston
1220 N. Market Street
Suite 608
Wilmington, DE 19801
Re: Curgg v. Hopkins (C.A. 1:04-CV-00175-JJF)
Dear Daniel:
We received your e-mail of June 24, 2008, and the attached draft of your
cross-motion to compel discovery.
You have offered to make OfHcer Hopkins available for a deposition on .
July 8, 2008, and Officer Taylor available for a deposition on July 10, 2008. We
are not available on July 8, 2008, but can take Officer Taylor’s deposition on July
10. Please provide an alternative date for Officer Hopkins' deposition. We are
available any day in July after July 14th, except for July 15th.
Unless we hear othenzvise from you, Officer Taylor’s deposition will begin
at 9:30 a.m. on July 10, 2008.
We note that the Dover Police Department, Officer Taylor and Officer Gott J
have still not responded to thesubpoenas the Plaintiff served on April 4, 2008.
" As such, these parties have waived their right to object to producing documents
responsive to the document requests found in those subpoenas. To avoid
having to continue Officer Taylor’s deposition, please produce all documents
responsive to these subpoenas at least 48 hours in advance of Officer Taylor’s _
deposition.
Sincerely,
Brian R. Lemon
cc: Scott E. Swenson, Esquire
Mr. Joseph Curry
l WILMINGTON, DE WASHINGTON, DC LOS ANGELES, CA

Case 1:04-cv-00175-JJF

Document 170-4

Filed 08/25/2008

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Case 1:04-cv-00175-JJF

Document 170-4

Filed 08/25/2008

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