Free Letter - District Court of Delaware - Delaware

Case 1:05-cv-00127-GMS

Document 9

Filed 05/19/2005

Page 1 of 2

Montgomery, McCracken, Walker & Rhoads, llp
attorneys at law Richard Montgomery Donaldson
Admitted in Delaware, Pennsylvania & New Jersey

300 Delaware Avenue, Suite 750 Wilmington, DE 19801 302-504-7800 Fax 302-504-7820

123 South Broad Street Avenue of the Arts Philadelphia, PA 19109 215-772-1500 Fax 215-772-7620 LibertyView 457 Haddonfield Road, Suite 600 Cherry Hill, NJ 08002 856-488-7700 Fax 856-488-7720 1235 Westlakes Drive, Suite 200 Berwyn, PA 19312 610-889-2210 Fax 610-889-2220

Direct Dial 302-504-7840

[email protected]

May 19, 2005 BY ELECTRONIC FILING The Honorable Gregory M. Sleet United States District Court for the District of Delaware 844 King Street, Lock Box 18 Wilmington, DE 19801 Re: Duffy v. Vincent Meconi, et al. C.A. No.: 05-CV-127-GMS

Dear Judge Sleet: I write in response to a call from Chambers this morning requesting further information about the Second Stipulation for An Extension of Defendant's Time to Respond to the Complaint and for Limited Initial Discovery, which was submitted for the Court's consideration yesterday. The defendants requested an additional one-week extension to respond to plaintiff's Complaint because the associate attorney at Montgomery McCracken who has been working on the draft response informed the firm that she was leaving the firm on May 27 (to move to Washington, D.C.). Her need to wrap up the various projects she was handling delayed the work she was doing on the defendants' filing. We informed plaintiff's counsel that the response was likely to be a motion to dismiss. Plaintiff's counsel graciously agreed to accommodate our firm's unanticipated staffing issue, and we took the opportunity to work out a more detailed briefing schedule (including page limitations for any reply and sur-reply briefs). Under these circumstances, we respectfully ask that the Court approve the stipulation negotiated by the parties.

A LIMITED LIABILITY PARTNERSHIP FORMED IN PENNSYLVANIA LOUIS A. PETRONI ­ NEW JERSEY RESPONSIBLE PARTNER

Case 1:05-cv-00127-GMS

Document 9

Filed 05/19/2005

Page 2 of 2

Montgomery, McCracken, Walker & Rhoads, llp

May 19, 2005 Page 2

Needless to say, I am at the Court's disposal should there be any further questions about the Second Stipulated Extension submitted for approval yesterday.

Respectfully submitted, /S/ Richard M. Donaldson Richard M. Donaldson (DE ID No. 4367) RMD/saa Enclosure cc: Dr. Peter T. Dalleo, Clerk (via e-service) Daniel G. Atkins, Esquire (via e-service) MaryBeth Musumeci, Esquire (via e-service)