Free Motion to Amend/Correct - District Court of Delaware - Delaware

Case 1 :04-cv-01565-SLR Document 89-5 Filed 01/26/2007 Page 1 of 1
. - IN THE UNITED STATES DISTRICT COURTS - _ _
_ · FOR THE DISTRICT OF DELAWARE " ·
· M. ADAMS, Chapter 11 Trustee of ·-‘»
· the Post-Confirmation Bankruptcy·Estates of . ·
A CORAM HEALTHCARE CORPORATION, 4 5 _ - _ 1
, a Delaware Corporation, and of CORAM, 4 » _ . i i
W INC., a Delaware Corporation, . · ~
‘ _ ' ‘ Plaintiffs, 1 Case No. 04-15 65 (SLR) ‘ ’ · A l
DANIEL D. CROWLEY . ` . ‘ .
· - A — Defendant · · A ~ S
A 1 _ DECLARATION OF R. JAMES SLAUGHTER
Y I PURSUANT TO D. DEL. LR; 7.1.1 I . ‘
` I, R. James Slaughter, declare and state: · L .
I V 1. A I am a partner with Kelcer & I/an Nest, LLP, counsel to Defendant Daniel D. ._ ,,__ _ _,_, ,,,___,,, S,
_ · l Crowley. I ani admitted to practice law in the State of California and have been admitted pro hac , · L_
. vice to appearbefore this Court. _ ` U p ` V _ —
, I 2. Pursuant to D. Del. LR. 7.1.1, Ihave made a reasonable effortto reach agreement _ -
with opposing counsel on the matters set forth in this motion prior to frling. On January 11, i _ »
_ 2007, my colleague Warren Braunig sent a letter by fax and U.S. mail to counsel for Plaintiff} _ .
_ seeking P1aintiff’ s consent to C1·owley’s amended `answer, attaching a copy of the proposed V
I · - Amended Answer, and seeking a response by January 17, 2007. Plaintiff responded through A
` _ counsel on January 23, 2007 that he would not oppose a motion for leavetto amend the Answer,
but nor would he consent to hit. 4 . _
I declare Wunder penalty of perjury under the laws ofthe United States that the foregoing is b ‘ A
true and correct. Executed on this 26th day of January 2007, at San Francisco, California.
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