Free Letter - District Court of Delaware - Delaware

Case 1 :05-cv-OOO72-JJF Document 233 Filed O9/28/2007 Page 1 of 2
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ATTORNEYS AND COUNSELLORS AT LAW TELEPHONE
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P. o. Box uso 3°;'f;;l:;`§6,
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September 28, 2007
The Honorable Joseph J. Farnan, Jr. VIA ELECTRONIC FILING AND
United States District Court HAND DELIVERY
844 King Street
Wilmington, DE 19801
Re: Wells Fargo Bank NA. v. Royal, Case No. 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 No. 05-72-JJF; and
Royal v. Pepper Hamilton, etal., Case No 05-165-JJF
Dear Judge Farnan:
We write on behalf of Royal Indenmity Company ("Royal"). In order to facilitate this
Wednesday’s pre-trial conference, enclosed please fmd courtesy copies of Royal’s motions in
limine, which address the following issues:
• Motion to exclude evidence regarding Roya1’s due diligence in connection
with the SFC transactions. As a matter of black-letter Pennsylvania law, Wells
cannot raise Royal’s alleged negligence as a defense to this breach of contract
action;
• Motion to exclude evidence regarding the conduct of SFC’s Attorneys and
Accountants. Wells cannot attempt to pass off its liability here onto the _
accountants and lawyers who perpetuated the fraud against Royal. Wells was
contractually obligated to protect Royal from precisely the conduct to which
Royal ultimately fell victim;
• Motion to exclude evidence regarding Royal’s alleged violation of Delaware
Insurance Code Section 909. Wells lacks standing to raise this argument, and
the Delaware Insurance Department, which closely monitored Royal at all

Case 1:05-cv-00072-JJF

Document 233

Filed 09/28/2007

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Case 1:05-cv-00072-JJF

Document 233

Filed 09/28/2007

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