Free Motion to Amend/Correct - District Court of Delaware - Delaware

Case 1 :96—cv—00523-Gl\/IS Document 94-4 Filed 12/12/2005 Page 1 of 1
MORRIS, JAMES, HITCHENS & WILLIAMS LLP
222 Delaware Avenue, 10th Floor 9
Wilmington, Delaware 19801-1621
(302) 888-6800
Facsimile (302) 571-1750
www.morrisjames.com
Edward M. McNally Mailing Address
(302) 888-6880 P.0. Box 2306
[email protected] Wilmington, DE 19899-2306
December 12, 2005
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, et al.
U.S.D.C., C.A. No. 96-523-SLR
Dear Judge Sleet:
I am the Court-Appointed Counsel for Plaintiff] Elberta Bernice Lieberman, in this
action. Enclosed is a courtesy copy of her Motion For Leave To Amend The Scheduling Order
which I have filed today. Counsel for the State, Marc Niedzielski, is on vacation. I have filed
the motion not wanting to delay it any further. When Mr. Niedzielski returns, I will take up with
him the State’s response to that motion.
While the motion seeks a limited extension of the Scheduling Order, I fully recognize
that extension may impact the other dates in the Order, including the trial date. For that reason, I
have not attached a proposed form of order to the motion. I appreciate that if the Court was
inclined to grant the motion, some further discussion would be required because of the impact it
will have on the other pre-trial and trial dates.
y Submitted,
Edward M. McNally (#6
EMM/gca
Enclosure
cc: Clerk of the District Court (via CM/ECP)
Marc P. Niedzielski, Esquire (via CM/ECF) 1
1318925/1
Dover (302) 678-8815 Broom Street (302) 655-2599 Newark (302) 368-4200