Free Letter - District Court of Delaware - Delaware

Case 1:07-cv-00465-SLR

Document 23

Filed 07/21/2008

Page 1 of 1

RICHARD R. WIER, JR., P.A.
ATTORNEY AT LAW RICHARD R. WIER, JR.* _______ TWO MILL ROAD, SUITE 200 WILMINGTON, DELAWARE 19806 www.Wierlaw.com [email protected] MAllen@ Wierlaw.com * ALSO ADMITTED IN PA (302) 888-3222 FAX (302) 888-3225

MICHELE D. ALLEN*

July 21, 2008 Via Electronic Filing The Honorable Sue Robinson United States District Court 844 North King Street Wilmington, DE 19801 Re: Parkstone v. New Castle County, et. al. C.A. No. 07-465 SLR

Dear Judge Robinson: We are writing your Honor to request a brief extension of the discovery deadline in the above referenced case. Discovery is currently scheduled to end on September 15, 2008. Due to both counsel's schedules, it is becoming increasingly difficult to complete discovery in this case by September 15, 2008. Therefore, we request a brief extension of discovery until October 15, 2008. Additionally, we request that the expert disclosure deadline be extended from July 30, 2008 until August 30, 2008 and disclosure of rebuttal expert witnesses be extended from August 30, 2008 until September 30, 2008. We do not believe that this brief extension will have any impact on any of the other dates in the scheduling order. Attached for the Court's convenience is a proposed order. We are available at the Court's convenience if there are any questions. Respectfully submitted,

RICHARD R. WIER, JR. P.A.

MARTIN & WILSON, P.A.

/s/ Michele D. Allen Michele D. Allen (#4359) Richard R. Wier, Jr. (#716) Two Mill Road, Suite 200 Wilmington, DE 19806 (302) 888-3222 telephone (302) 888-3225 facsimile [email protected] [email protected] Attorneys for Defendants

/s/ Timothy J. Wilson Timothy J. Wilson (#4323) Jeffrey K. Martin (#2407) 1508 Pennsylvania Avenue Wilmington, DE 19806 (302) 777-4681 - telephone (302) 777-5803 - facsimile [email protected] [email protected] Attorneys for Plaintiff

Case 1:07-cv-00465-SLR

Document 23-2

Filed 07/21/2008

Page 1 of 1

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF DELAWARE DENNIS E. PARKSTONE, III Plaintiff v. CHRISTOPHER A. COONS, individually and in his official capacity; RICHARD PRZYWARA, individually and in his official capacity; and NEW CASTLE COUNTY, a municipal corporation, Defendants. : : : : : : : : : : : : : :

C.A. No. 07-465-SLR

JURY TRIAL DEMANDED

ORDER

IT IS ORDERED this

Day of

2008 that discovery in the above referenced case is

hereby extended until October 15, 2008. Reports from any retained experts under Rule 26(a)(2) on issues for the party who has the burden of proof are hereby extended until August 30, 2008. Rebuttal expert reports are hereby extended until September 30, 2008.

______________________________ The Honorable Sue L. Robinson