Free Letter - District Court of Delaware - Delaware

Case 1:05-cv-00298-JJF Document 75 Filed 08/25/2005 Page 1 of 1
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BY E—FILE
The Honorable Joseph 5. Farnan, Jr.
United States District Court
For the District of Delaware
844 North King Street
Wilmington, Delaware 19801
Re: Frank D. Seinfeld v. Craig R. Barrett, et al.,
D. Del.. CA. 05-2.98-JJF
Dear Judge Farnan:
As Your Honor may recall, defendants have requested oral argument (DI. 73) on
plaintiff s motion for summary judgment (Dir 5) and on their two motions to dismiss: for failure
to comply with Fed.R.Civ.P. .23.] and for lack of subject matter jurisdiction (Di. I5 and D.I. iQ).
Plaintiff does not oppose defendants’ request for oral argument on all three motions (DI. 74).
Defendants believe that oral argument is important given the unusual procedural posture of this
case and the issues presented by defendants’ motions. Plaintiff` s motion for summary judgment
was brought only weeks after his complaint was tiled and was made without the beneiit of any
discovery. Defendants’ motions to dismiss raise issues about whether the complaint is ripe and
whether it complies with the important demand requirement imposed by both Federal and
Delaware law. Defendants are available to appear for oral argument on October 4, 12, 19, 20
and 26. If Your Honor’s assistant would provide me with potential dates for the oral argument, l
would be happy to coordinate scheduling with the parties and the Court-
I am available at Your I—lonor’s convenience.
Respectfull
Stephen C. Norrnan (#2686)
snor·n1an@potte1·a11dersorrcom
SCN/mp:696357
cc: Clerk of the Court (By E—Fiie)
Francis G. X. Pileggi, Esquire (By E~File)