Free Motion for Miscellaneous Relief - District Court of Delaware - Delaware

Case 1:06-cv-00224-JJF

Document 18

Filed 06/22/2006

Page 1 of 2

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF DELAWARE

SAMUEL I. HYLAND, individually and on behalf of all others similarly situated, Plaintiff, v. J.P. MORGAN SECURITIES, INC., a Delaware corporation, Defendant.

Civil Action No. 06-224 JJF

CLASS ACTION

PLAINTIFF SAMUEL I. HYLAND'S MOTION TO MODIFY THE PSLRA'S STAY OF DISCOVERY

Plaintiff Samuel I. Hyland ("Plaintiff") respectfully requests that this Court issue an Order directing defendant J.P. Morgan Securities, Inc. to produce to Plaintiff all documents that have been and will be produced to plaintiff in Blau v. Harrison, No. 046592 (N.D. Ill.). In accordance with Local Rule 7.1.1, Plaintiff sought the concurrence of counsel to defendant in the relief requested by this motion, but defendant's counsel refused to make available the subject document production. In support of this motion, Plaintiff incorporates herein by reference the opening brief filed herewith. DATED: June 22, 2006 Respectfully submitted, /s/ Joseph N. Gielata JOSEPH N. GIELATA (# 4338) Attorney at Law 501 Silverside Road, No. 90 Wilmington, Delaware 19809 (302) 798-1096 Attorney for Plaintiff Samuel Hyland

Case 1:06-cv-00224-JJF

Document 18

Filed 06/22/2006

Page 2 of 2

CERTIFICATE OF SERVICE I hereby certify that, on June 22, 2006, I electronically filed PLAINTIFF SAMUEL I. HYLAND'S MOTION TO MODIFY THE PSLRA'S STAY OF DISCOVERY with the Clerk of Court using CM/ECF which will send notification of such filing to: Michael R. Robinson, Esq. RICHARDS LAYTON & FINGER , P.A. One Rodney Square Wilmington, DE 19801 Counsel for Defendant

/s/ Joseph N. Gielata Joseph N. Gielata (# 4338)

Case 1:06-cv-00224-JJF

Document 18-2

Filed 06/22/2006

Page 1 of 1

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF DELAWARE

SAMUEL I. HYLAND, individually and on behalf of all others similarly situated, Plaintiff, v. J.P. MORGAN SECURITIES, INC., a Delaware corporation, Defendant.

Civil Action No. 06-224 JJF

CLASS ACTION

[PROPOSED] ORDER Having considered Plaintiff Samuel I. Hyland's Motion To Modify The PSLRA's Stay Of Discovery, and for good cause shown, defendant J.P. Morgan Securities, Inc. and its parent company JPMorgan Chase & Co. are hereby directed to produce to Plaintiff copies of all documents and any other discovery produced to the plaintiff in Blau v. Harrison, 04-6592, presently pending in the Northern District of Illinois. IT IS SO ORDERED. DATED: ________________, 2006

UNITED STATES DISTRICT JUDGE HONORABLE JOSEPH J. FARNAN, JR.