Free Notice (Other) - District Court of Delaware - Delaware

Case 1:04-cv-01534-KAJ

Document 28

Filed 09/19/2005

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IN THE UNITED STATES DISTRICT COURT IN AND FOR THE DISTRICT OF DELAWARE MARTIN DURANT, Plaintiff, v. PERFECT CARE NURSES, INC., Defendant. : : : : : : : : :

C.A. No. 04-1534 (KAJ)

JURY TRIAL DEMANDED

NOTICE OF COMPLETION OF BRIEFING FOR DEFENDANT'S MOTION FOR PARTIAL SUMMARY JUDGMENT 1. On August 31, 2005, Defendant, Perfect Care Nurses, Inc., filed its Motion for

Partial Summary Judgment (DI 24). 2. On September 15, 2005, Plaintiff, Martin Durant, filed his Response to the

Motion for Partial Summary Judgment (DI 27). Plaintiff does not oppose the substantive relief sought in the Motion for Partial Summary Judgment, but does oppose the Defendant's request for costs. 3. Defendant hereby waives its right to file a reply brief in support of the Motion for

Partial Summary Judgment. Defendant also hereby waives its request for costs associated with the Motion for Partial Summary Judgment. 4. Accordingly, briefing is complete on the Motion for Partial Summary Judgment.

There being no opposition to the substance of the Motion for Partial Summary Judgment, Defendant respectfully requests entry of an order in the form annexed hereto. 5. necessary. Defendant stands ready to discuss this matter at the convenience of the Court, as

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Case 1:04-cv-01534-KAJ

Document 28

Filed 09/19/2005

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Respectfully submitted, WHITE AND WILLIAMS LLP

By:

Dated: September 19, 2005

/s/ Marc S. Casarino Christian J. Singewald (Bar No. 3542) Marc S. Casarino (Bar No. 3613) 824 N. Market Street, Suite 902 P.O. Box 709 Wilmington, DE 19899-0709 (302) 467-4520 (302) 467-4550 facsimile Attorneys for Perfect Care Nurses, Inc.

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