Free Letter - District Court of Delaware - Delaware

Case 1 :04-cv-01551-JJF Document 94 Filed 05/31 /2006 Page 1 of 1
Eckert Seamans Cherin & IVIe|lott, LLC TEL 302 425 0430
300 Delaware Avenue, Suite 1360 FAX 302 425 0432
‘ · Wilmington, DE 19801 vvwvv.eckertseamans.com
Karen Lee Tumer _
215.85l.843l
[email protected]
May 31, 2006
VIA ELECTRONIC FILING
The Honorable Joseph J. Farnan, Jr.
United States District Court
District of Delaware
844 N. King Street
Room 4124, Lockbox 27
Wilmington, DE 19801
Re: Stanziale v. Pepper Hamilton LLP, et al., No. 04-1551
Dear Judge Farnan: .
This firm represents defendants W. Roderick Gagné, Robert L. Bast, Pamela Bashore Gagné and
the seven Trusts named as defendants in the above-captioned civil action. We are writing this
letter in response to the Court’s May 18, 2006 Order, in which Your Honor directed each party to
submit a letter setting forth its position on any issues remaining in dispute after the parties
attempted to negotiate a joint scheduling order and deposition coordination plan.
We agree with the positions set forth in the letter being submitted to you on behalf of defendants
Pepper Hamilton LLP and W. Roderick Gagné (the "Pepper Defendants"), in which the Pepper
Defendants state that they agree with the proposed Case Management Order submitted by Royal,
but that they do not agree with the proposed length of depositions in section I.A. of the draft
Discovery Coordination Order submitted by Royal, and propose alternative limits on deposition
` length. We agree to the other terms of the draft Discovery Coordination Order submitted by
Royal.
We look forward to answering any questions Your Honor has on our position during the `
conference on June 1. .
Respectfully yours,
_ Karen Lee Turner
KLT:bkk
cc: All counsel on attached service list
- M0553458.DOC ‘
WILMINGTON, DE PITTSBURGH, PA HARRISBURG, PA PHILADELPHIA, PA BOSTON, MA WASHINGTON, DC ·
· MORGANTOWN, WV SOUTHPOINTE, PA ALCOA CENTER, PA