Free Letter - District Court of Delaware - Delaware

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Case 1:07-cv-00129-MPT Document 55 Filed 07/O2/2008 Page 1 of 2
LAW OFFICES HAROLD SCHMITFINGER
NICHGI-AS H. RQDRIGUEZ SCHMITTINGER AND RODRIGUEZ, P.A. me - me
JOHN J. SCHMITTINGER {
DOUGLAS B. CA·rrs 414 SOUTH STATE STREET MICHELE PROCINO-WELLS
WILLIAM D. FLETCHER, JR. OF COUNSEL
CRAIG T. ELIAssEN ··—
WILLIAM W. PEPPER SR. DOVER, DELAWARE 19901 , NEwARK OFFICE {
CRYSTAL I., CAREY* * TELEPHONE 3O2_674_O14O CI-IRIGTIANA EXECUTIVE CAMPUS
?§§ST$+$.$£ZS§§$I.. FAX 302-674-1830 22°Ni$.'1"§Z?“S.§iI$’E$EE‘I€%Z Z"'
NOEL E. PRIMOS TELEPHONE 302—894-1960 I
DAVID A. BOSWELL FAX 302-894-1965
WALT F. SCHMITFINGER {
R. SCOTT KAPPES REI-I¤aoTI-I BEACH OFFICE
JEFFREY J. CLARK WAcI-IovIA BANK BUILDING I
KYLE KEMMER 18489 COASTAL HIGHWAY, 2ND FLR {
KATI-IRYN J. GARRISON REI-IOEoTI-I BEAcI-I, DELAWARE 19971
ERIN K. FIUGERALD TELEPHONE 302-227-1400
KRISTI N. Vrr0LA FAX 302—645—1843
B. BRIAN BRI1·nNG•-IAM
MIDDLETOWN OFFICE l
*AI-S¤ A¤M¤'I'é¤ IN MARYLAND 651 N. BROAD STREET, STE 104
‘ MIDDLETOwN, DELAWARE 19709
TELEPI-IoNE 302—378·1697
FAX sez-ave-1659 {
July 2, 2008 {
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The Honorable Mary Pat Thynge
United States District Court
844 North King Street
Lock Box 8 {
Wilmington, Delaware l980l — .
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VIA ELECTRONIC FILING {
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RE: La on v. Lobb House Inc.
C.A. No.: O7—l29—MP'I‘
Dear Judge Thynge: }
The above—referenced action is scheduled for a four—day jury trial
before your Honor beginning September 8, 2008. At this time, I am
respectfully requesting a continuance of the trial on behalf of my {
client, Shannon Laymon.
Ms. Laymon has been accepted to Widener University Law School and
will begin her studies on August 20, 2008. With the stress of the
first semester of law school, together with the responsibilities
of a full—time job, it would be extremely stressful for my client
to participate in a trial in federal court less than 3 weeks after
she begins her studies. We are requesting a continuance until
after the beginning of 2009——i.e., until after Ms. Laymon’s first
semester is completed.
I raised the matter of the proposed continuance with Defendant’s ·
counsel, Mr. Poliquin, by telephone last week. Mr. Poliquin has {
indicated in a written communication that his client is opposed to {
the request. I have not been informed of the basis for the
opposition. With all due respect to Mr. Poliquin’s client, it is
Plaintiff’s position that Defendant would suffer no significant {
prejudice from this relatively brief delay. 5
In a teleconference in an unrelated matter yesterday, I learned I
that your Honor will be out of chambers for much of this month. I

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Case1:O7-cv-OO129—|\/IPT Document 55 Filed 07/O2/2008 Page20f2 é
July 2, 2008 g
Page 2 i
However, IK would. respectfully‘ request consideration. of this l
request as soon as possible. Plaintiff requests that, should the 2
Court continue the trial, the pretrial conference be continued as
well. The pretrial conference is currently scheduled for August
21, 2008, with the pretrial stipulation due to be filed on August
8, 2008. Therefore, a prompt decision regarding this continuance
request would guide the parties in their preparation for trial. g
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Thank you for your consideration of this request.
Respectfully, 1
" » l
NOEL E. PRIMOS J
cc: Ronald G. Poliquin, Esquire (by e—filing)
Ms. Shannon Laymon {
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