Free Letter - District Court of Delaware - Delaware

Case 1:05—cv—00300-JJF Document 158 Filed 12/14/2006 Page 1 of 2

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December 14, 2006
VIA E-FILE ANI) HAND DELIVERY
The Honorable Joseph J. Faman, Jr.
United States District Court
District of Delaware
Lock Box 27
844 N. King Street, Room 4209
Wilmington, DE l980l
Rc: Creedon Controls, Inc. v. Banc One Building Corporation
and Forest Electric Corporation, C.A. No. 05-CV-300 gJJF[
Dear Judge Farnan:
This office represents Forest Electric Corporation. Please accept this letter as a brief
response to plaintiff eounsel’s December 5, 2006 letter. Defendants have requested that the
pretrial conference occur on the first available date after the completion of expert depositions on
January 15,2007.
Plaintiffs counsel made various statements about the scheduling of the deposition of
Forest Electric’s expert. I offered various dates for that deposition, including November 2l and
22, 2006. Counsel claims that I failed to give any explanation as to my expert’s later
unavailability on November 22, 2006. Indeed, I explained to plaintiffs counsel that I mistakenly
provided that date (which was the Wednesday before Thanksgiving) and that the proper dates
should have been November 20 and 21, 2006. Plaintiff s counsel said that he was surprised that
anyone wanted to conduct a deposition the day before Thanksgiving, especially in light of travel
problems related to that time around the holiday. He agreed without hesitation to allow difierent
dates to be supplied understanding the situation.
I have not manipulated availability of Forest’s expert but, due to schedules, I was unable
to offer dates other than November 20 (which was not accepted) and the time period of
January I0 through January l9, 2007. Plaintiffs counsel accepted January I5, 2007 by noticing
the deposition for that date.
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Case 1:05—cv—00300-JJF Document 158 Filed 12/14/2006 Page 2 of 2
'I`he Honorable Joseph J. Faman, Jr.
December 14, 2006
Page 2
I will provide any additional infomation should Your Honor deem it necessary.
Respectfully submitted,
Paul A. Bradley
PAB/lav
cc: Counsel of Record
Clerk ofthe Court
{8200:00001 xw0114012.}