Free Letter - District Court of Delaware - Delaware

Case 1:98-cv-00061-MPT

Document 183

Filed 04/15/2005

Page 1 of 2

Mary E. Copper

Partner Attorney at Law [email protected] 302 984-6020 Direct Phone 302 658-1192 Fax

April 15, 2005 VIA E-FILING Magistrate Judge Mary Pat Thynge U.S. District Court for the District of Delaware 844 North King Street Lock Box 8 Wilmington, DE 19801 Re: Dear Judge Thynge: Pursuant to the April 4, 2005 teleconference in the above-referenced matter, the parties have conferred and jointly submit the following proposal for how to handle the outstanding issues in this case. First, the parties will be permitted to engage in discovery limited to the issues of (a) Plaintiff's entitlement to an award of prejudgment interest, and (b) the appropriate method of calculation of any prejudgment award. This discovery period will close sixty (60) days from April 15, i.e., June 14, 2005. Second, the above issues will be submitted for final decision by way of post-remand briefing, to be completed based on the following schedule: Plaintiff's Opening Brief Defendant's Answering Brief Plaintiff's Reply Brief July 15, 2005 August 15, 2005 September 6, 2005 Skretvedt v. DuPont, C.A. No. 98-CV-61

The parties will be limited to thirty (30) pages for the opening and answering briefs, and fifteen (15) pages for the reply. Should Your Honor have any questions concerning the above proposal, counsel are available at the Court's convenience. Very truly yours, /s/ Mary E. Copper Mary E. Copper (D.I. No.: 2397) cc:
/678246

John M. Stull, Esquire

Case 1:98-cv-00061-MPT
Magistrate Judge Mary Pat Thynge April 15, 2005 Page 2 bcc:

Document 183

Filed 04/15/2005

Page 2 of 2

Mary Jo Anderson, Esq. (by electronic mail) Evelyn H. Brantley, Esq. (by electronic mail) Kathleen Furey McDonough, Esq. Sarah E. DiLuzio, Esq.