Free Letter - District Court of Delaware - Delaware

Case 1:04-cv-01457-KAJ Document 23 Filed 06/29/2005 Page 1 of 1
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June 29, 2005
The Honorable Kent A. Jordan
United States District Court
844 King Street
Lock Box 10
Wilmington, DE 19801
RE: ,|ohn R. Baker v. Town of Smyrna
Civil Action No.: 04-1457 (KAJ)
Dear Judge J ordan:
Please consider this as a joint status report regarding the above-captioned matter.
Plaintiffs Initial Disclosures Made Pursuant to Federal Rule of Civil Procedure 26 (a)(1) were filed
and served on Defendant on Wednesday, June 29, 2005. Defendant served Plaintiff with Initial
Disclosures Made Pursuant to Federal Rule of Civil Procedure 26 (a) (1) on January 5, 2005. On
January 11, 2005, Defendant served Plaintiff with Defendant‘s First Set of Interrogatories and
Request For Production directed to Plaintiff. Plaintiff anticipates servicing Defendant with its First
Set of Interrogatories and Request For Production within the next few days. Both parties have
agreed to complete discovery by September 1, 2005. Both parties have also agreed and are
requesting the Court's permission to extend the Disclosure of Expert Testimony deadline to
September 30, 2005.
The oral deposition of the Plaintiff was taken on February 23, 2005, and the oral depositions of
Theopolas Banes, Defendant Joseph Heeger and Defendant Harvey Leggett were taken on March
22, 2005.
A mediation conference is scheduled for Wednesday, September 7, 2005, beginning at 10:00 a.m.
Both parties have agreed to waive the interim status conference call scheduled for July 6, 2005.
Should the Court feel that the conference call is necessary, however, counsel stand ready to
participte.
Re ctfully submitted,
_ = J]
. ." .· ,- T ’
AM D. FLET R, JR.
cc: Noel E. Primos, Esq.
Bruce C. Herron, Esq. ""`