Free Letter - District Court of Delaware - Delaware

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

Document 88

Filed 04/04/2005

Page 1 of 1



Smith Katzenstein Furlow LLP
Attorneys at Law April 4, 2005 VIA E-FILING The Honorable Joseph J. Farnan, Jr. U.S. District Court for the District of Delaware 844 N. King Street Wilmington, DE 19801 Re:

The Corporate Plaza 800 Delaware Avenue, 7th Floor P.O. Box 410 Wilmington, DE 19899 (Courier 19801) Telephone: (302) 652-8400 Telecopy: (302) 652-8405 www.skfdelaware.com

Spoltore v. Wilmington Professional Associates, Inc., C.A. No. 04-125 JJF

Dear Judge Farnan: We represent the defendant in the above referenced matter. I am writing to respond briefly to Mr. Saputelli's letter to Your Honor of April 1, 2005 requesting that the pretrial conference and trial be adjourned for thirty days. As Mr. Saputelli correctly stated, defendant does not oppose plaintiff's request that the pretrial conference and trial be rescheduled. However, we believe that a new pretrial conference and trial should not be scheduled until after Thursday, when Magistrate Thynge hears argument regarding the five discovery motions at issue. At that time, it should become clear as to the amount of time that will be necessary to complete discovery. If Your Honor has any questions regarding defendant's position, I am available at the convenience of the Court. Respectfully, /s/ Laurence V. Cronin Laurence V. Cronin (ID No. 2385) cc: Clerk of Court (via e-filing) The Honorable Mary Pat Thynge (via hand delivery) Steven T. Davis, Esquire (via e-filing) Gregory D. Saputelli, Esquire (via facsimile)

10001376.WPD