Free Letter - District Court of Delaware - Delaware

Case 1:05-cv-00022-MPT

Document 212

Filed 08/01/2008

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 1, 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. We are in receipt of the Response of plaintiffs St. Paul Mercury Insurance Company and Pack& Process to the Petition to Approve Settlement and Compromise of Wrongful Death and Survival Actions and Designation of Beneficiaries ("Petition"), filed with the Court on July 31, 2008. Of note, the Vong defendants were not kept apprised of the status of discussions between plaintiffs and the remaining defendants concerning either the Release or the Petition, nor were the Vong defendants made aware by plaintiffs of their concerns. From the electronic mail message appended as Exhibit A to the Response, it appears that plaintiffs' communications in that regard were with counsel for the remaining defendants and not with the undersigned or with Philadelphia counsel for the Vong defendants. The Vong defendants believe that the concerns raised by plaintiffs in their Response can be easily addressed through an office conference with Your Honor, if not sooner. Therefore, the Vong defendants respectfully request an office conference with the Court to discuss plaintiffs'

Case 1:05-cv-00022-MPT

Document 212

Filed 08/01/2008

Page 2 of 2

PERRY & SENSOR
August 1, 2008 Page 2 concerns so that a final version of both the Release and the Petition may be completed without further delay. In the meantime, now that the Vong plaintiffs are aware of the concerns raised by plaintiffs, we will work with plaintiffs to resolve these issues as expeditiously as possible. Counsel stand ready at the call of the Court should Your Honor have questions or concerns regarding the above request. Respectfully submitted, PERRY & SENSOR /s/ Michael L. Sensor By: MLS/mls cc: Yvonne Takvorian Saville, Esquire (via electronic filing) Raj Srivatsan, Esquire (via electronic filing) Robert S. Miller, Esquire (via U.S. Mail) Richard Costigan, Esquire (via U.S. Mail) Warren I. Siegel, Esquire (via U.S. Mail) Steven M. Dranoff, Esquire (via U.S. Mail) Michael L. Sensor (# 3541)