Free Letter - District Court of Delaware - Delaware

Case 1:06-cv-00593-JJF Document 49 Filed 08/29/2008 Page 1 of 1
c;HAo M. SHANDLER
Director
302-651 -7836
SI—[email protected]
August 29, 2008
VIA HAND DELIVERY AND ELECTRONIC FILING
The Honorable Joseph J. Faman, Jr.
United States District Court
844 King Street
Wilmington, DE 19801
Re: 3V, Inc. v. CIBA Specialty Chemicals Corporation, C.A. No. 06-00593-JJF;
CIBA Specialty Chemicals Corporation v. 3V, Inc., C.A. N o. 06-00629-JJF;
CIBA Specialty Chemicals Corporation v. 3V, Inc., C.A. No. 06-00672-JJF
Dear Judge Farnan:
We write to respectfully request that Your Honor schedule a status conference at
the earliest convenience of the Court. It seems that 3V, Inc. ("3V") has taken the position that its
pending motion to dismiss negates the need for it to participate any further in this litigation.
However, even if 3V is successful in having its own claims dismissed, its motion does not
resolve the claims asserted by CIBA in the consolidated actions. CIBA would like to complete
discovery and prepare these consolidated cases for trial. Without 3V’s cooperation, however, the
dates set forth in the Court’s revised scheduling order (D.I. 29 and 30) are in peril. Rather than
burden the Court with motions to compel at this time, we thought it would be more efficient to
have a brief conference with the Court to discuss certain pretrial matters and to set a trial date.
Respectfully submitted,
/s/ Chad M Shandler
Chad M. Shandler (#3796)
CS:ps
cc: Clerk of Court (via e-filing)
Joseph Grey, Esq. (via hand delivery)
Alan J. Branigan, Esq. (via electronic mail)
Rrri-tazsvzss-2 ' ' '
One Rodney Square I 920 North King Street I Wilmington, DE 19801 I Phone: 302-651-77OO I Fax: 302-651-7701
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