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Case 1:04-cv-00175-JJF Document 170-2 Filed 08/25/2008 Page 1 of 3
EXHIBITU

Case 1:04-cv-00175-JJF Document 170-2 Filed 08/25/2008 Page 2 of 3
gy ` CON NOLLY BOVE LODGE 8e HUTZ LLP
E ATTORNEYS AT LAW
WILMINGTON, DE
The Nemours Building
Brian R_ Lemon 1007 North Orange St.
TEL (302) 888-6319 RO. Box 2207
E’.t‘rrE3él§2..i?.§Lt1§,..m W¤·mt~gr¤¤· DE 19899
REPLY To Wilmington Office TE'—= (302) 558 9141
FAX: (302) 658 5614
Jung 26, WEB: www.cblh.com
VIA FACSIMILE AND U.S. MAIL
Daniel A. Griffith, Esquire
Whlteford Taylor & Preston
1220 N. Market Street
Suite 608
‘ Wilmington, DE 19801
` Re: Curry v. Hopkins (C.A. 1:04-CV-00175-JJF)
Dear Daniel:
This letter memorializes the oral agreement reached by the parties.
ln an effort to solve the disputes between the parties without intervention
by the Court, the parties agree:
(1) To stipulate that the Defendant’s responses to the Plaintiffs
motions (D.l. 158 and D.l. 160) are not due until August 18,
2008;
(2) To stipulate that the Plaintiffs replies are not due until August
25, 2008;
(3) To stipulate that the Plaintiff may continue to take fact discovery
until August 15, 2008;
(4) That Defendant’s counsel will produce all outstanding ·
documents by July 7, 2008, including, but not limited to:
i. Documents relating to insurance policies; ·
ii. The Defendant’s lA and personnel files on an attorney’s
eyes only basis;
(5) That the Defendant will reply to the Plaintiffs third set of
interrogatories by July 7, 2008;
(6) That the Defendant will provide a complete response to the
Plaintiffs lnterrogatory No. 6;
(7) That Ofhcer Taylor will attend a deposition in Plaintiffs
counsel’s offices before July 31, 2008; ‘
(8) That Ofhcer Gott will attend a deposition in Plaintiffs counsel’s
ofhces before July 31, 2008;
(9) That Officer Hopkins will attend a deposition in Plaintiffs
counsel’s offices before July 31, 2008;
WILMINGTON, DE WASHINGTON, DC LOS ANGELES, CA

Case 1:04-cv-00175-JJF Document 170-2 Filed 08/25/2008 Page 3 of 3
(10) That any dlscoverable documents found to exist but that were
not previously produced will be produced by August 6, 2008;
(11) That the Plaintiff will withdraw its motions (D.l. 158 and D.l.
160) by August 18, 2008, upon completion of all the above.
(12) That the parties waive any objections to the timeliness of
discovery taken or requested prior to August 15, 2008.
Please respond and let us know whether the Defendant agrees that the
above represents the entire agreement between the parties.
Sincerely, Q
Brian R. Lemon
cc: Scott E. Swenson, Esquire
l\/lr. Joseph Curry

Case 1:04-cv-00175-JJF

Document 170-2

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Case 1:04-cv-00175-JJF

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