Free Letter - District Court of Delaware - Delaware

Case 1 :96-cv—00523-GIVIS Document 97 Filed 01/06/2006 Page 1 of 2
MORRIS, JAMES, HITCHENS & WILLIAMS LLP
222 Delaware Avenue, 10th Floor
Wilmington, Delaware 19801-1621
(302) 888-6800
Facsimile (302) 571-1750
, www.morrisjames.com
Edward M. McNally Mailing Address
(302) 888-6880 P.O. Box 2306
[email protected] Wilmington, DE 19899-2306
January 6, 2006
VIA CM/ECF AND HAND DELIVERY
The Honorable Gregory M. Sleet .
United States District Court
844 North King Street
Lock Box 19
Wilmington, DE 19801
RE: Lieberman v. State of Delaware, etal.
U.S.D.C., C.A. No. 96-523-SLR
Dear Judge Sleet:
In accordance with the terms of the Scheduling Order, Plaintiff Bernice Lieberman I
delivered her draft pre-trial order on December 7, 2005.
On January 5, 2006, the State provided its comments to the pre-trial order. A colleague
of mine has also been working diligently with the State to resolve differences in the jury
instructions.
Unfortunately, my 84-year-old mother is now in the emergency room at Wilmington
General Hospital and may need a fairly immediate operation. Therefore, I am distracted.
On behalf of the State, Marc Niedzielski has kindly agreed to an extension until next
Wednesday, January ll, 2006, to file the pre-trial order and jury instructions with the Court. The
pre-trial conference itself is not until January 31, 2006.
Dover (302) 678-8815 Broom Street (302) 655-2599 Newark (302) 368-4200

Case 1 :96-cv—00523-GIVIS Document 97 Filed 01 /06/2006 Page 2 of 2
The Honorable Gregory M. Sleet MORRIS, ]AMEs, HITCHENS & WILLIAMS LLP
January 6, 2006 ·
Page 2
Under these circumstances, I hope that the Court will consider entering the attached
Order extending the date to file a pre-trial order and jury instructions.
Respectfully Submitted,
/7 I

Edward McNally (#614)
EMM:bes
Attachment
cc: Clerk of the District Court (via CM/ECF)
Marc P. Niedzielski, Esquire (via CM/ECF)
is27474/1