Free Letter - District Court of Delaware - Delaware

Case 1:07-cv-00435-SLR

THE NEUBERGER FIRM
ATTORNEYS AND COUNSELLORS AT LAW
TWO EAST SEVENTH STREET SUITE 302 WILMINGTON, DELAWARE 19801-3707
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Document 24

Filed 10/01/2007

Page 1 of 2

THOMAS S. NEUBERGER, ESQUIRE STEPHEN J. NEUBERGER, ESQUIRE RAEANN WARNER, ESQUIRE CHERYL A. HERTZOG, ESQUIRE*
*(Licensed in PA and NJ only)

PHONE: (302) 655-0582 FAX: (302) 655-9329

October 1, 2007 VIA HAND DELIVERY and CM/ECF The Honorable Sue L. Robinson Lock Box 31 United States District Court District of Delaware 844 King Street Wilmington, DE 19801

RE:

Issuance of a letter to prepare a Rule 16 scheduling order Quill v. Catholic Diocese of Wilmington, et al., C.A. No. 07-435 (SLR)

Dear Judge Robinson: There are three sets of defendants in this case which was brought in diversity under the new Child Victim's Act of 2007: The Catholic Diocese and its Bishop, St. Elizabeth's Church and Rev. Francis DeLuca. Anthony Flynn has filed an Answer for the Diocese and Bishop. Mark Reardon has answered for the Church. Steve Casarino represents defendant DeLuca but has received more time to Answer due to the unavailablity of his client who is serving a 60 day term of imprisonment in New York. An Answer will be filed after defendant DeLuca is released. By stipulation Mr. Flynn and I also are separately briefing a diversity issue. But as D.I. 18 indicates, the parties agreed that "discovery can, and should proceed during" the pendency of the motion. Since these Answers to the Complaint have been filed by the main defendants, I respectfully request that the Court issue a letter directing the parties to draft a discovery plan and report back to the Court. I also will include Mr. Casarino in the process.

Case 1:07-cv-00435-SLR

Document 24

Filed 10/01/2007

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The Honorable Sue L. Robinson October 1, 2007 Page 2

Respectfully yours, /s/ Thomas S. Neuberger Attorney for Plaintiff

cc:

Anthony G. Flynn, Esquire (via File & Serve) Mark L. Reardon, Esquire (via File & Serve) Stephen P. Casarino, Esquire (via US Mail) Thomas C. Crumplar, Esquire (via File & Serve) Robert Quill (via E-Mail)