Free Letter - District Court of Delaware - Delaware

Case 1:05-cv-00022-MPT

Document 216

Filed 08/20/2008

Page 1 of 2

PERRY & SENSOR
ATTORNEYS AT LAW
JAMES T. PERRY
*

MICHAEL L. SENSOR*
*ALSO ADMITTED IN NEW JERSEY

ONE CUSTOMS HOUSE, SUITE 560 POST OFFICE BOX 1568 WILMINGTON, DELAWARE 19899

(302) 655-4482 FACSIMILE (302) 655-4043

August 20, 2008 The Honorable Mary Pat Thynge Magistrate Judge U.S. District Court for the District of Delaware J. Caleb Boggs Courthouse 844 N. King Street Wilmington, DE 19801 VIA ELECTRONIC FILING Re: St. Paul Mercury Ins. Co., et al. v. Maly Yan, et al. C.A. No. 05-0022 (MPT) (Consolidated) Yan Thou, et al. v. Pack & Process, Inc., et al. C.A. No. 05-0513 (MPT) (Consolidated) Dear Magistrate Judge Thynge: This firm is local counsel to defendants Unchalee Vong, Lawrence Vong, Zair Shah, Khan Gul, Salim Khan, Mohammad Sardar Khan, Rahamat Pari and the several children of Mohammad Azim, Soly Chan, Thorn Bun Khem, Kusti Leman, Asan Hujani Oh, and Tjajah Chandra ("the Vong defendants") in the above-captioned consolidated matters. Your Honor has scheduled a follow-up teleconference for tomorrow, August 21, 2008 commencing at 11:00 a.m. to further discuss the matters surrounding the Release and Settlement Agreement in this case. My purpose in writing is to respectfully request that I be excused from participating in this teleconference as local counsel, as I have a previously-scheduled court appearance in New Castle County Superior Court on that date at 10:30 a.m. in the matter of Milligan v. Erie Insurance Exchange, et al., C.A. No. 07C-11-171 FSS; I do not expect to be completed with that court appearance before this teleconference begins. Lead counsel for the Vong defendants in this matter, Messrs. Miller, Costigan, Dranoff, and Siegel, have been actively involved in discussing the Release and Settlement Agreement with counsel for co-defendants and plaintiff; as such, I expect them to be fully prepared to address these issues without my involvement. I stand at the call of the Court should Your Honor have any questions or concerns regarding this request.

Case 1:05-cv-00022-MPT

Document 216

Filed 08/20/2008

Page 2 of 2

PERRY & SENSOR
August 20, 2008 Page 2

Respectfully submitted, PERRY & SENSOR /s/ Michael L. Sensor By: MLS/mls cc: Yvonne Takvorian Saville, Esquire (via electronic filing) Royce W. Smith, Esquire (via electronic mail) Chad J. Toms, Esquire (via electronic filing) Robert S. Miller, Esquire (via electronic mail) Richard Costigan, Esquire (via electronic mail) Warren I. Siegel, Esquire (via electronic mail) Steven M. Dranoff, Esquire (via electronic mail) Michael L. Sensor (# 3541)