Free Reply to Response to Motion - District Court of Delaware - Delaware

Case 1:05-cv-00284-GI\/IS Document 9-3 Filed 06/07/2005 Page1 0f 2
EXHIBIT 2

"°‘;CaQs‘*e2f1Q?5}é1\}§ClO;2?84—GlV|S Document 9—§l3232.l°§iIg% 0%/0];/2;768g179Qii’age F2 [gil/BB
§,J1J;|¢\.·,*:!·P‘•!
. _h .,
DE-10-NEWC * P.O. Box 15260 ’ Wilmington, DE 19850-5260
May 4, 2005
Quarles & Brady Q
Attn: Monica Tynan, Esq.
500 W. Madison Street
STE 3700
Chicago, IL 60661
OUR INSURED : Sara S Echevarria
OUR CLAIM NUMBER : 89 07 497126 05152004 01
DATE OF ACCIDENT : 05·15·2004
CLAIMANT NAME : Sara S Echevarria
‘ Dear Ms. Tynan,
I have attached the copy ofthe police report we have regarding this case. As we discussed, I
see no problem with removing the case to Federal Court. I discussed this with my defense
attorney, Rob Leoni after we spoke, and he agreed that there was no issue on our part with your
request. ‘
As we had also dismissed, I see this as a matter that involves additional defendants not yet
named, speciiically the manufacturer of the hitch and/or coupling mechanism on the U-Haul
trailer unit. I understand that someone at U-Haul may have had the unit examined, but I am
uncertain if that is indeed the case. My concerns about a possible defect here are based on the
infomation we have iiom the police report that defendant Mayfield, had recoupled the unit in
North Carolina, some three hundred miles away from where this incident took place.
Please let me know if there is anything else I can help you with.
N RAL INSURANCE COMPANY .
Sonja Blackhawk
Claims Department
(302)325—8932
C:
Morgan, Shelsby & Leoni
13] Continental Drive STE 206
Newark DE 19713