Free Letter - District Court of Delaware - Delaware

Case 1 :07—cv—00674-SLR-LPS Document 43 Filed 05/05/2008 Page 1 of 1 2
YoUNc· CoNAwAY STARGATT & TAYLOR, LLP
THE BRANDYWINE Burtnmo
1000 WEsT STREET, 17TH FLOOR
BARRY M WFLLGUGHBY Wiuvunoron, DELAWARE 19801 (302) 571-6600
DIRECT Dm.; (302) 571-6666 (302) 571-1253 FAX
Dnuscr rAx: (302) 576-3345 P.O. Box 391 (800) 253-2234 (DE ONLY)
[email protected] W{LM{NGTON’ DELAWARE 19399-039] www.youngc0naway.com
May 5, 2008
VIA CM-ECF i
The Honorable Leonard P. Stark
United States District Court
844 North King Street, Lock Box 26
Wilmington, DE 19801
Re: Dougherty v. ASDI, Inc.
Civil Action No. 07-674-SLR/LPS
Dear Judge Stark: ~
I am writing to request that the Court schedule a telephone or in-office status conference in
the above matter. There are presently pending before the Court Plaintiffs Motion to Amend his
Complaint, Defendant’s Motion to Compel Discovery, Defendant’s Motion to Stay, and Defendant’s
Motion for Judgment on the Pleadings and/or to Dismiss Plaintiffs State Law Claims for Lack of
Jurisdiction. Plaintiff has requested an oral argument on his Motion to amend the Complaint.
Depositions of Defendant, Alan Blize, and Defendant, ASDI’s Human Resources Manager,
Trula Blize, are scheduled for several days the week of May 19, 2008. Defendant believes that these
depositions should be postponed to allow the Court time to consider the various motions before it,
including Defendant’s request for a stay, pending consideration of Defendant’s jurisdictional motion.
Accordingly, Defendant respectfully requests that the Court schedule a telephone or in-office status
conference in connection with these matters.
I attempted to reach Plaintiffs counsel, Mr. Holly, earlier today. Mr. Holly is out of the
office until tomorrow. I am requesting that he advise the Court with respect to his position on the
requested status conference upon his return.
Respectfully,
:/Q"-\
I Barry M. Willoughby (LD. 1016)
BMW:mmcm
cc: Clerk, U.S. District Court
Timothy Holly, Esquire
I Margaret M. DiBianca, Esquire
DB02;6796s31.1 066253.100;+

Case 1:07-cv-00674-SLR-LPS

Document 43

Filed 05/05/2008

Page 1 of 1