Free Letter - District Court of Delaware - Delaware

- · Case 1 :04-cv-00125-JJF-MPT Document 89 Filed O4/O1/2005 Page 1 of 2
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Civil Trial Attumcy
File No.: 4l 104-00l
April 1, 2005
Vin Hand Delivery
The Honorable Joseph J. Farnan, Jr.
United States District Court
For the District of Delaware
844 N. King Street
Room 4124
Lock Box 27
Wilmington, DE 19801
Re: Andrea L. Spoltore, f/k/a Andrea L. Cadwallader v.
Wilmington Professional Associates, Inc.
Docket No.: 04-125 JJF
Dear Judge Farnan:
We represent the Plaintiff in the above-captioned case.
I am writing to respectfully request a 30-day adjournment of both the pretrial conference, now
scheduled for April 7, 2005 at 1:30 pm, and the trial, now scheduled for May 23, 2005. Laurence V.
Cronin, Esquire, counsel for the defendant, has indicated to us that he is not opposed to putting off the
pretrial conference, and that he does not believe that the case will be ready for trial in May, but that he
will be writing separately to Your Honor on Monday with his reasoning. q
The reasons for Plaintiff’s request are as follows:
(l) A mediation that had been scheduled to be conducted on the morning of April 7, 2005, -
has been converted to a hearing on various discovery motions that were filed last fall and will now be J
heard by Magistrate Judge Mary Pat Thynge on that moming, the same date on which the pretrial T
conference is scheduled. Plaintiffs counsel believes that the content ofthe pretrial stipulation will be J
impacted, and will need to reflect, the substance of the Court’s rulings on the motions, which will not
be able to be accomplished until after April 7. 2006.
(2) There is an outstanding deposition to be taken of Plaintiff’s expert, the scheduling of _
which was delayed until after the previously scheduled mediation, which has now been converted to a
motion hearing. In addition, I understand that Mr. Cronin may request that other depositions be taken
after April 7, 2005, depending on Magistrate Judge Thynge’s rulings on the outstanding motions. l
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- · Case 1:04-cv-00125-JJF—MPT Document 89 Filed O4/O1/2005 Page 2 of 2
OBERMAYER REBMANN MAX\VELL & HIPPEL LLP
The Honorable Joseph J. Farnan, Jr.
United States District Court
For the District of Delaware
April 1, 2005
Page 2
Testimony to be provided during any remaining deposition(s) may also impact the content ofthe
pretrial stipulation.
Thank you for Your I-Ionor’s consideration of this request.
espectfully yours,
..\ »
REG Y D. SAPU LL
GDS/pjs
cz Magistrate Judge Mary Pat Thynge
Laurence V. Cronin, Esquire (Via Fax & Regular Mail)
Steven T. Davis, Esquire
Andrea L. Spoltore
at
l.
610346

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

Document 89

Filed 04/01/2005

Page 1 of 2

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

Document 89

Filed 04/01/2005

Page 2 of 2