Free Motion for Discovery - District Court of Delaware - Delaware

Case 1:98-cv-00061-MPT

Document 189
SUITE 700

JOHN M. STULL
ATTORNEY AT LAW

Filed 07/15/2005

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1300 NORTH MARKET STREET POST OFFICE BOX 1947

WILMINGTON, DELAWARE 19899-1947 --(302) 654-0399 Fax: (302) 654-0884

July 14, 2005

Magistrate Judge Mary Pat Thynge U. S. District Court for District of Delaware Lock Box 8 844 North King Street Wilmington, DE 19801 Re: Skretvedt v. DuPont Company, et.al., C.A. 98-61 (MPT); Joint Stipulation of Parties for extension of time beyond July 15, 2005, in which to complete discovery; Order; Withdrawal of Deposition Notice for July 14, 2005 of DuPont witnesses; Deposition per Rule 30(b)(6)

Dear Judge Thynge: Due to the complications of information sought and unavailability of witnesses being considered for deposition this date, the parties, through counsel, have mutually agreed and Stipulated that the current deadline for discovery needs to be extended to September 2, 2005, in order to provide a fair and mutually acceptable opportunity for submission of data and responses thereto. I therefore submit this letter request via e-filing for a Stipulation of extension along with an Order reflecting the advancement of dates for briefing, response, and reply consistent with the Court=s prior Order, subject to approval of the Court. Also to be submitted via e-filing is a Withdrawal of Notice of Deposition previously Noticed for July 14, 2005, and a new Notice of Deposition per Rule 30(b)(6) seeking a response from DuPont Company as deponent via agents, managers, and the like. The parties have appreciated the Court=s past considerations and request further flexibility as needed to resolve factual matters.

Case 1:98-cv-00061-MPT JOHN M. STULL, ESQ. Magistrate Judge Mary Pat Thynge July 14, 2005 Page 2

Document 189

Filed 07/15/2005

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Respectfully submitted,

/s/ JOHN M. STULL John M. Stull JMS/prs cc: Mary E. Copper, Esq. Kathleen Furey McDonough. Esq. Sarah E. DiLuzio, Esq.

enclosures: Stipulation and Order Withdrawal of Notice of Deposition Notice of Deposition per rule 30(b)(6)