Free Letter - District Court of Delaware - Delaware

Case 1 :06-cv-00097-JJF Document 30 Filed O3/27/2007 Page 1 of 1
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March 27, 2007
Honorable Joseph J. Farnan, Jr.
District of Delaware
844 North King Street
Wilmington, DE 19801
Re: National Fire & Marine Insurance Company v. Robin James Construction
Inc.
C.A. No. 06-97
Damages Hearing: April 2, 2007 @ 11:00 a.m.
Dear Judge Farnan:
As Your Honor is aware, by Order entered March 22, 2007, summary
judgment was entered in favor of the Plaintiff and a damages hearing was set for April 2,
2007 at 11:00 a.m. Kindly accept this correspondence as Plaintiff s request for a
continuance of that hearing. Co-counsel has been unable to reach the witness to date who
is located in Nebraska as she is apparently out of the office on vacation. An alternative
witness has not been found thus far and additional time is also needed in order for travel
arrangements to be made. Plaintiff would also respectfully request whether video
conferencing or telephonic participation by the witness is possible.
In addition, my co-counsel who has been handling the case, advised my office on
March 26, 2007 that she has accepted other employment effective March 29, 2007, so
some additional time is requested for another attorney to familiarize himself with the case
and speak with the witness.
1 have spoken with Mr. Howard who represents the Defendant and he does not
oppose this request. The Court’s indulgence is greatly appreciated.
Respectfully submitted,
[Elise ’/
Kristi J. Ddughty t
cc: Eric Howard via facsimile