Free Letter - District Court of Delaware - Delaware

Case 1 :07-cv-00387-JJF Document 28 Filed 05/30/2008 Page 1 of 2
4 ··`‘‘ f Eckert Seamans Cherin & I\/Iellott, LLC rat 302 425 0430
. 300 Delaware Avenue, Suite 1210 mx 302 4220432
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Margaret F. England
(302) 425-0430
[email protected]
May 30, 2008
Via Hand Delivery and Electronic Filing
The Honorable Joseph J. Parnan, Jr.
United States District Court
J. Caleb Boggs Federal Building
844 North King Street
Wilmington, DE 19801
Re: Delsie E. Brookens v. General Motors Corporation, et al.
United States District Court, District of Delaware ‘
Case No. 07-387 QJJFI
Dear Judge Farnan:
As you know, this law firm represents General Motors Corporation and a number of other
General Motors entities (hereinafter collectively "General Motors") in the above referenced
lawsuit. On May 12, 2008, Your Honor entered an Order regarding the Plaintiffs ability to tile
an answering brief to General Motors’ Motion for Summary Judgment, which was timely filed
on March 31, 2008.
Under the Order, the Plaintiff had until May 27, 2008 to file an answering brief. On that
date, Plaintiff filed a Motion for Extension of Time to file her Motion for Summary Judgment
and a Motion for Extension of Time to file an Answering Brief to General Motors’ Motion for
Summary Judgment. On May 28, 2008, Plaintiff filed a brief in support of and in response to
General Motors Motion for Summary Judgment. This brief was not electronically filed and was
not received by General Motors until late on May 29, 2008.
General Motors objects to the Plaintiff being able to file the brief after the deadline.
Your Honor’s Order entered on May 12, 2008 was clear that if the brief was not filed on May 27,
2008 that the Court would rule on the papers. Plaintiff failed to comply with this Order and
should not be allowed to make a late submission.
WILMINGTON, DE PITTSBURGH, PA HARRISBURG, PA PHILADELPHIA, PA BOSTON, IVIA WASHINGTON, DC
IVIORGANTOWN, WV SOUTHPOINTE, PA WHITE PLAINS, NY I

Case 1 :07-cv-00387-JJF Document 28 Filed 05/30/2008 Page 2 of 2
The Honorable Joseph J. Farnan, Jr.
I United States District Court
December 17, 2007
Page 2
Thank you for your consideration in this matter. If you have any questions, or need any
additional information, feel tree to contact me.
Respectfully,
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Margare M. England
cc: David M. Davis, Esq. (via electronic mail)
John Stull, Esq. (via First Class Mail)
WILMINGTON, DE PITTSBURGH, PA I-IARRISBURG, PA PI-IILADELPI-IIA, PA BOSTON, IVIA WASHINGTON, DC
IVIORGANTOWN, WV SOUTHPOINTE, PA ALCOA CENTER, PA