Free Letter - District Court of Delaware - Delaware

Case 1:04-cv—01380-G|\/IS Document 50 Filed 04/29/2005 Page 1 of 1
As1—1eY 8. GEDDES
ATTORNEYS AND COUNSELLORS AT LAW '|’¤|—¢•’H°N€
302-654-IGBB
222 DELAWARE AVENUE
FACSIMILE
P. O. BOX M50 aca-s¤4-=¤¤v
WILMINGTON, DELAWARE 19899
April 29, 2005
VL4 HAND DELIVERY
The Honorable Gregory M. Sleet
United States District Court for
the District of Delaware
844 North King Street, Room 4209
Wilmington, DE 19801
RE: In re GST Telecom, Inc., et ol. (Case N0. 00-01982 (GMS))
GST Telecom, Inc., et ol. v. John Worm (Civil Action No. 04cv]380 (GMS))
Dear Judge Sleet:
We write on behalf of John Warta in connection with GST’s pending Motion for Fees
and Costs (the "GST Motion") (D.l. 29) to bring to the Court’s attention facts relevant thereto.
As referenced in his response to the GST Motion, Mr. Warta was of the belief that GST
met and conferred with the proposed deponent, Mr. Goodrich, respecting his testimony or this
litigation generally. See Warta Response at fl 16 (D.I. 33). Since the submission of Mr. Warta’s
response, we have confirmed that GST did, in fact, meet and confer with Mr. Goodrich in Palo
Alto, CA, as confirmed by Mr. Goodrich’s deposition testimony (the relevant portion of the
deposition transcript, pp. 98-101, is attached hereto as Exhibit A).
Should the Court have any questions regarding this matter, we are available at the Court’s
convenience.
Respectfully submitted,
Ricardo Palacio
RP/kmm
Enclosure
cc: Joseph Arellano, Esq. (w/ encl.)
Daniel Keppler, Esq. (w/ encl.)
Steven Yoder, Esq. (w/ encl.)
William Gibbons, Esq. (w/ encl.)
156607.1