Free Letter - District Court of Delaware - Delaware

Case 1:O4—cv-01416-JJF Document 67 Filed O1/13/2006 Page 1 of 1
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The Honorable Joseph I. Farnan, Ir.
U.S. District Court for the District of Delaware
844 N. King Street
Wilmington, DE l980l
RE: Jersey Shore Automation v. Chuguch Support Services
C.A. No. 044416 (UF)
Dear Judge Farnan:
This letter is responsive to Chagaclfs letter dated January 6, 2006 (D.l. 66), wherein
Chugach requests the Court to defer ruling on Connolly ]3ove’s Motion to Withdraw (the
"Motion"). Connolly Bove respectfully requests that Your Honor consider the Motion in light of
the parties’ inability to agree on a proposed stipulation and form of order which would allow
Connolly Bove to withdraw while protecting Cl1ugaeh’s and Jersey Sbore’s interests. As Your
Honor may recall, Chugaclfs opposition to Connolly Bove’s Motion suggested that Connolly
Bove be permitted to withdraw provided that judgment be entered against Jersey Shore if it did
not obtain counsel within 30 days from the date of withdraw (D.}, 62).1 Connolly Bove has
offered Chugach a stipulation consistent with its opposition papers, yet Chugacb has not been
agreeable and has been demanding additional concessions. Consequently, the parties have been
unable to reach agreement on this issue.
fjiespecttully, 1, M.
Q { M if ` " `-r·' ` P 4,,,
"' Janies D. Heisman
5 ,,.: r '
xc: Harvey A. Levin, Esq. (via facsimile & U.S. mail)
Jersey Shore Automation (via certified and U.S. mail)
439408/12866*1
I Jersey Shore is agreeable to the entry of such an Order.