Free Letter - District Court of Delaware - Delaware

Case 1 :07-cv-0071 ument_21_____________lfi_l_e _ _ §/QZ/2008 Page 1 of 2

Wilmington, DE 19806
Timothy Wilson, Esquire* Telephone: (302) 777-4681
Facsimile: (302) 7`7`7·5803
*Ligen_·;gd in DE, PA and N] www.martinandwilson.com
August 7, 2008 Email: twilson martinandwilsoncom
Hon. Joseph J. Faman, Jr.
U.S. District Court for the District of Delaware
J. J. Caleb Boggs Federal Building
844 N. King Street
Room 4124
Lockbox 27
Wilmington, DE 19801
I/D1: ELECTRONIC FILING AND HAND DELIVERY
Re: Romdhani v. ExxonMobil, No. 1:07-cv-715
Dear Judge Farnan:
Please find enclosed a courtesy copy of Plaintiff s Unopposed Motion for Leave to File Second
Amended Complaint, along with a copy of the Second Amended Complaint.
Plaintiff s Second Amended Complaint voluntarily removes any claims opposed by Defendant in
its Motion to Dismiss and to Strike that was filed in December 2007 and which is still outstanding
(Defendant moved to dismiss Plaintiffs Delaware Discrimination in Employment Act claims).
Therefore, Defendanfs Motion is now moot.
Plaintiffs initial Complaint was filed in November 2007, but due to Defendanfs outstanding
motion, the parties have not had an opportunity to engage in discovery — something Plaintiffs are
certainly eager to do in order to move this case forward. Accordingly, Plaintiffs respectfully request that
the Court issue a Scheduling Order in this case, or set a status conference to discuss this matter so that
Plaintiffs can proceed with discovery.

Case 1 :07-cv-00715-JJF Document 21 Filed 08/07/2008 Page 2 of 2
Counsel is available should Your Honor wish to confer e his matter.
' ec rm ed,
(A q { r v v
• * . Wil n
nrney fo * laintiffs
Enclosures
cc: Avi Kumin, Esquire
Joseph Caldwell, Esquire, Counsel for ExxonMobil (by e-mail and iirst—class mail)

Case 1:07-cv-00715-JJF

Document 21

Filed 08/07/2008

Page 1 of 2

Case 1:07-cv-00715-JJF

Document 21

Filed 08/07/2008

Page 2 of 2