Free Letter - District Court of Delaware - Delaware

Case 1 :04-cv-001 25-JJ F-l\/I PT Document 99 Filed 05/O2/2005 Page 1 of 2
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Smith
KRtZC“$t€iH The Corporate Plaza
Furlow LLP 800 Delaware Avenue. 7th Floor
Attorneys at Law P·O· Box 410
Mhlmington, Delaware l9899
(Courier 19801)
Phone (302) 652-8400
Fax (302) 652-8405
Craig H" Smith www.skfdelawarc.com
Robert Karzeustcin May 2,
David A. jenkins
Laurence V. Cronin
VIA E-FILING
Michele C. Gott
Kathleen M. Miller
anger n. Andaman The Honorable Mary Pat Thynge
JM": E, polcsk,. U. S. District Court for the District of Delaware
Rohm K- BCM 844 North King Street
Wilmington, DE 19801
Etta R. Wolfe
Re: Spoltare v. WilmingtonPr0fessi011aIAss0ciates, Inc., C.A. N0. 04-125 JJF
Dear Judge Thynge:
Pursuant to the Court’s order of March 18, 2005, Judge Faman referred to Your Honor
the pending discovery motions in the above referenced matter. (D.I. 85). At a hearing
on April 7, 2005, all pending discovery motions were resolved in favor of the
defendant. (D.I. 92). As part ofthe Court’s order resolving these motions, the parties
were ordered to submit by April 25 a proposed schedule for the the completion of
discovery.
Subsequent to entry of the April 7 order and entry of a stipulated protective order on
April 13 (D.I. 94), plaintiff produced documents that had either been previously
withheld or produced only in a redacted form. These documents identify additional
facilities where plaintiff has recently received treatment. As a result, I informed
plaintiffs counsel that we intended to serve subpoenas on the three institutions at issue
so that we could obtain their records conceming plaintiff prior to the resumption of her
client`s deposition on May 12, 2005. Ms. Sutton has indicated in response that she will
move to quash those subpoenas. As a result, we have agreed not to serve the subpoenas
and plaintiffs deposition has been postponed pending resolution of this dispute.
I am writing for the purpose of requesting an office conference or teleconference to
discuss how best to complete discovery in this matter without the need for additional
10002273.wPD
02428 CORR

Case 1:04-cv—OO125-JJF—MPT Document 99 Filed 05/O2/2005 Page 2 of 2
The Honorable Mary Pat Thynge
May 2, 2005
Page 2
expensive and time consuming motion practice. At present, it does not appear possible
for the parties to even propose a schedule for the completion of discovery when we
continue to have a fundamental disagreement as to both the scope of discovery and the
meaning ofthe Court’s rulings on April 7. If the Court is amenable to proceeding in
this manner, I would pleased to assist in scheduling a time convenient to both the
parties and the Court. lf Your Honor has any questions regarding this request, I am
available at the convenience of the Court.
full
Respree} , i
Laurence V. Cronin (ID No. 2385)
LVCfvl<;m
cc: Clerk of Court (via eyiling)
Steven T. Davis, Esquire (via ejiling)
Kimberly D. Sutton, Esquire (vinfacsimiie)
iuon2m.w1>o
02428 conn


Case 1:04-cv-00125-JJF-MPT

Document 99

Filed 05/02/2005

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Case 1:04-cv-00125-JJF-MPT

Document 99

Filed 05/02/2005

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