Free Letter - District Court of Delaware - Delaware

Case 1 :07-cv-00178-GIVIS Document 8 Filed 05/O3/2007 Page 1 of 2
Potter
E Anderson
* Corroon ur
13}.3 North Market Sonet :
PO. Box 951
Wilmington, DE 19899-0951 .
302 984 6000
www.pottera11derson.eom E
Philip A. Rovner
Partner
pE’OVl'i€I'@fJOl`E€f3.X}(lf5l'SOIk.C0lT1
(302) 9S4—6l40 Direct Phone ‘
(BO2)658-1z92 Fax
May 3, 2007
BY E—FILE
The Honorable Gregory M. Sleet
United States District Court for the District of Delaware _
U.S. Courthouse
844 North King Street
Wilmington, DE l980l
Re: Monte-Carlo Country Club et al. v. ATP Tour, Inc., et ol.,
D. Del., CA. No. 0’7~l98·GMS;
Deutscher Tennis Bunol et nl. v. ATP Tour, Inc., et al.,
D. Del., CA. No. 07-178-GMS ·
Dear Judge Sleet:
This firm, along with Sidley Austin LLP, represents plaintiffs in the action entitled,
Monte—Corlo Country Club et al. v. ATP Tour, Inc., et ol., D. Del., C.A. No. 07-198-GMS (the `
"Monte Carlo Action"). We write not only on behalf of the Monte Carlo plaintiffs but on behalf .
of all parties in the Monte Carlo Action as well as all parties in the related action assigned to .
Your Honor entitled, Deutscher Tennis Bunol et ol. v. ATP Tour, Inc., et ol., C.A. 07··l78·~Gi\/IS
(the "Hambw·g Action”), to request a Rule 16 conference at the Court’s earliest convenience to
consider the [Proposed] Coordinated Scheduling Order (attached hereto). For the reasons stated
below, the parties believe that the proposed order serves the interests of judicial economy and the I
particular circtunstances of these related actions, and respectfully request that the Court use it as .
the basis for its controlling order for both cases.
Both the Monte Carlo and the Hamburg Actions concern a plan to alter certain aspects of
the ATP men's professional tennis circuit beginning in 2009. The parties agree that, given the
common aspects of the cases and the nature ofthe issues involved, it would serve the interests of
judicial economy to have discovery and pretrial proceedings in these cases proceed in a
coordinated fashion. The parties also agree that, if at all possible, trial should be scheduled in the e
first third of 2008. While that date is approximately twelve months from the date of the initiation
of the two actions, the minimum time set forth in this Court’s local rules, the disputes raised in 2

Case 1:07-cv-00178-G|\/IS Document 8 Filed 05/O3/2007 Page 2 of 2 ‘
The Honorable Gregory M. Sleet
May 3, 2007
Page 2
the complaints need to be resolved sufficiently in advance of the 2009 tennis season to enable the
parties and other affected entities to prepare adequately for that season.
To meet these objectives, the parties have met and conferred, and were able to reach
agreement on the terms ofthe enclosed [Proposed] Coordinated Scheduling Order. Should Your
Honor have any questions, counsel are available at the Conrt’s convenience.
Respectfully,
» Philip A. Rovner
[email protected]
PAR/mes/793 149
Eno.
cc: Alan M. Unger, Esq. — w/encl. M by E-mail
Robert D. MacGil1, Esq. — w/encl. —- by E-mail ·
C. Barr Flinn, Esq.- w/enc]. — by ECP and E——mail
Bradley l. Ruskin, Esq, — w/encl. — by E»mail
. Lawrence C. Ashby, Esq. — by EGF and E·-mail
Philip Trainer, Jr., Esq. —· by ECF and E-mail