Free Letter - District Court of Delaware - Delaware

Case 1 :05-cv-00072-JJF Document 62 Filed 05/31 /2006 Page 1 of 4
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ATTORNEYS AND COUNSELLORS AT LAW TELEPHONE
222 oE|.AwARE AVENUE °°2`°°4"°°°
P. O. BOX |l5O 30;f;§m;-($67
wu.M|NGTON, DELAWARE @899
May 31, 2006
VIA E-FILE AND HAND DELIVERY
Honorable Joseph J. Farnan, Jr.
United States District Court
District of Delaware
J. Caleb Boggs Federal Building
844 N. King Street
Room 4124, Lockbox 27
Wilmington, Delaware 19801
• Wells Fargo Bank N.A. v. Royal, Case N0. 02-1294-JJF;
• Charles A. Stanziale, Jr., Chapter 7 Trustee of Student Finance Corp. v.
Pepper Hamilton, et al., Case No. 04-1551-JJF;
• Charles A. Stanziale, Jr., Chapter 7 Trustee of Student Finance Corp. v.
McGladrey & Pullen LLP, et aL, Case N0. 05-72-JJF; and
• Royal v. Pepper Hamilton, et al., Case No 05-165-JJF
Dear Judge Faman:
I write on behalf of Royal Indemnity Company ("Royal"), which is a party in two of the
referenced cases, as well as Charles Stanziale, as Trustee, the plaintiff in the other two cases,
who joins in this submission.
As requested by the Court at the hearing in this matter held on May 17, 2006, the parties
met and conferred several times to determine if they could agree on case management schedules
in each of the four cases and a. joint case coordination plan. That process began with a nearly all-
day meeting at the office of counsel for Royal, which was followed by the exchange of numerous
written proposals and comments by the parties, and two all-counsel telephone conference calls.
There is a divergence of opinion among the parties (who essentially fall into one of two
groupings) about when depositions in these cases should start, the length of time necessary to
complete those depositions and other fact discovery, and an appropriate trial range.

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