Free Reply Brief - District Court of Delaware - Delaware

Case 1:04-cv-01380-G|\/IS Document 35-3 Filed O3/O4/2005 Page1 of 3
Exhibit B
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Case 1:04-cv-01380-G|\/IS Document 35-3 Filed O3/O4/2005 Page 2 of 3
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OCT 2 8 2004
1 IN THE UNITED STATES EAm 2 IN AND FOR THE DISTRICT OF DELAWARE
3 .. ... ...
4 In re: : Chapter ll
5 GST TELECOM INC., et al., I Case No. OO—19B2(GMS)
6 Debtors. I (Jointly Administered)
7 .. .. ...
8 Wilmington, Delaware
Thursday, October 7, 2004
9 10:00 a.m.
In Chambers
10
ll
BEFORE: HONORABLE GREGORY M. SLEET, U.S.D.C.J.
12
APPEARANCES:
13
RICARDO PALACIO, ESQ.
14 Ashby & Geddes, P.A.
~and—
( 15 CHRISTOPHER H. KENT, ESQ., and
A LESLIE S. JOHNSON, ESQ.
16 Kent Custis, LLP
(Portland, Oregon)
17
Counsel for John Warta
18
CHRISTOPHER WARD, ESQ.
19 The Bayard Firm
—and—
20 WILLIAM GIBBONS, ESQ., and
DANIELLE KEMP, ESQ. E
21 Latham & Watkins LLP
(Chicago, Illinois)
22
Counsel for GST
23
24
25
I
I

Case1:O4—cv—O1380-GMS Document 35-3 Filed O3/O4/2005 Page30f3
1 discussion that are in dispute. ,
2 We will resolve the discovery dispute during the
l 3 TC. If we don't, we will engage in a letter~writing process,
4 a little less expansive in terms of the number of pages than
5 permitted here on the privilege issue, two pages, two pages,
6 that kind of thing, unless I determine that I would benefit
7 from full briefing. Then I will release you to do that,
8 engage in full—blown motions practice. It generally doesn't
9 happen.
l 10 So that's the way you raise discovery matters
11 with the Court. As well as, not just disputes over
12 inadequate responses to interrogatories alleged, but matters
13 related to the schedule and things of that nature. Don't
14 file motions in this chambers to expand, for instance, the
, 15 fact discovery deadline. If you have an interest in
A 16 addressing my discretion on an issue like that, what you need
17 to do is talk, send over a stipulation, with an explanation
18 as to why you want the relief that you are requesting.
19 Let's say it's an extension of the fact discovery
20 deadline. I would like a detailed explanation as to why you
21 have not done what you have agreed that you can do today, and
22 otherwise I am going to get you on the phone and we will talk
23 about it. I really don't like having to do that, to
24 re—circle back, because it takes time.
25 Okay. Amendment and joinder, I think counsel