Free Reply Brief - District Court of Delaware - Delaware

Case 1:04-cv-01380-G|\/IS Document 35-2 Filed O3/O4/2005 Paget of 2
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Case 1 *04-cv-01380 G|\/IS
‘ · Document 35-2 ‘
Filed 03/04/2005 Page 2 of 2
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Ianuary 28, 2005
VLA FACSIMILE & MAIL
i Danielle S. Kemp, Esq.
_ Latham & Watkins
233 S Wacker Drive, Ste. 5800
Chicago, IL 60606
Re: In Re GST Telecom, Inc., et al.
U.S. Bankru tc Con District of Delaware Case No. 004982 GMS
Our File N0.: 1285-004
Dear Danielle:
ln response to your letters of January 21 and 26 and 27, we are not authorized to
respond on substantive issues on John Wsrta’s behalf pending our formal withdrawal.
With respect to the announcement of another 18 boxes of records for production, I
am sure the new counsel would appreciate some description ofthe nature of the records
before making a decision on review versus copying.
ltbink your complaints about the passage of a few days given the months of
inactivity on the depositions are unfair. As Joe Arellano, our successor, reported to Judge
Thynge, he is presently in a trial that is likely to last through at least next week. Even so,
we are meeting today with his team to take further steps in transition ofthe case. We
have no intention of letting the transition cause slippage of the Court’s scheduled cut-off
dates, as evidenced by Joe’s participation in the scheduling conference with Judge
Thynge one court day after his retention.
V truly yo
S. Johnso I
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Cc: Joseph C. Arellano via thx
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