Free Letter - District Court of Delaware - Delaware

Case 1 :05-cv—OO468-GIVIS Document 46 Filed 05/O9/2006 Page 1 of 3
TIGHE, COTTRELL & LOGAN, P.A.
ONE C USTOM HOUSE
P. O. BOX 103I
WILMINGTON DELAWARE 19899
Telephone Number: ( 302 ) 658-6400
Telecopier Number: (302} 658-9836
Toll Free: (800) 645·64'0]
WRITER ’S EMAIL: m. righe @1'awzcl.c0m
BRANCH 01=1=rc12s.·
Am1.1AT1zr> wrrrr 110 wear ROAD 2017 srrrrrvc GARDEN STREET
19 WESTAVENUE $1117*12 245 1>1=11r.Ar>1a11,1>1r1A,r>A101s0-s1sr0.r
120. rox 303 I Towson M0 21204
wooosroww, NJ 08008
It/iay 9, 2006
BY ELECTRONIC FILING
The I-ionorabie Gregory I\/I. Steet
U.S. District Court
Lock Box 19
844 North King Street
Wiirnington, DE 19801
RE: Davidson v. Harrington Raceway et. ai.
C.A. N0.: 05-468 (GIVES)
Our File No.: 8561
Dear Judge Sleet: ‘
1 ern in receipt of Mr. Erharfs ietter to you of it/lay 9, 2006 regarding discovery issues in this
case. Mr. Erhart describes his letter as a joint submission. i\/ir. Erharts letter is not a ioint
submission. ’
It is not true that Defendants have not answered interrogatories. lnterrogatory answers were
served on lVlr. Erhart this morning.
lt is not true that “rie documents except for Plaintiffs medical records have been produced by
Defendants? Response to F’iaint1tf’s Request for Production was served on lVlr. Erhart this morning.
With regard to the sunreiltance tape, a response to request tor production indicates how that
tape was put together. We are asking the Ciient to produce any additionai tapes that exists.
t attach an e-mail sent to me by Mr. Erhart on Monday, l\/lay 8, 2006 indicating that he
intended to send the letter that he utttmately sent. i aiso attach my response indicating that discovery

Case 1:05-cv-00468-G|\/IS Document 46 Filed 05/O9/2006 Page 2 of 3
responses were being served upon I\/Er. Erhart. That was in fact done by band delivery.
Respoctfuily submitted, l
T1GI·—EE, COTTRELL & LOGAN
/s/Michael K. Tighe
Michel K. Tighe
NIKT/jab
cc: \/Viltiam W. Erhart, Esquire
Clerk of the Court

Case 1 :05-cv—OO468-GIVIS Document 46 Filed 05/O9/2006 Page 3 $@56 I OH
Michael Tighe .
From: "Michael Tighe"
To: "erhartw"
Cc: "Iashina person" ; "Matt Lindauer" ; "thomas
· fIanagan“
Sent: Tuesday, May 09, 2006 9:13 AM
Subject: Re: Peoples/Davidson v Gaming Entertainment discovery dispute
Bill,
This morning, we will be sewing upon you veritied interrogatory answers and responses to requests for
production. There will remain items to be provided which we are making a concerted effort to obtain and get to
you. In addition, we are working out the confidentiality agreement covering the logs you requested. I apologize for
the delay in responding to your discovery.
Mike
———~— Original Message —~~——
From:
Tc:
Sent: Monday, May 08, 2006 6:‘l3 PM
Subject: Peopleslllavidson v Gaming Entertainment discovery dispute
Mike:
Pursuant to the courts order l intend to send a letter by 2 pm tomorrow i\/lay 9 as follows:
interrogatories have not been answered.
No documents except for P's medical records have been produced.
Only an edited surveillance tape has been produced.
Effect of delays
. if you want something added to the agenda letter, please let me know. _
William VV. Erhart
William W. Erhart, P.A.
800 King Street, Suite 302
Vlhimingtcn, DE 19801
(302) 651-01 t 3 (voice)
(302) 651-0331 (fax)
NOTICE: This e-mail message and all attachments transmitted with it may contain legally privileged and
contidential information intended solely for the use ofthe addressee. if you are not the intended recipient, you
are hereby notified that any reading, dissemination, distribution, copying, or other use of this message or its
attachments is strictly prohibited. li you have received this message ln error, please notify the sender
immediately by electronic mail or by telephone (302) 651-0113 and delete this message and any copies or
backups. Thank you.
5/9/2006