Free Letter - District Court of Delaware - Delaware

Case 1 :04-cv-01374-SLR Document 31 Filed 06/24/2005 Paq/Ie 1 of 2_ .
cCarter & English, LLP ·
Suite 1800
919 N. Market Street
Michael P. Kelly R0. BOX 111
_ Wilmington, DE 19899
M¤¤¤e¤¤e Perm ra s¤z.ss4.ss¤u
[email protected] fax 3029846399
wwwmccartercom
@%litiH§§
June 24» 2005 Arronrlevs AT LAW k
The Honorable Sue L. Robinson
U. S. District Court
for the District of Delaware
844 North King Street, Room 4209
Lock Box 18
Wilmington, DE 19801 ‘
Re: Pamela Graebar v. Mother's Work (
C.A. N0. 04-CV-1374 SLR
Dear Judge Robinson:
I am writing on behalf of both parties to seek an extension of the dates for the close of discovery
(presently scheduled for July 1, 2005) and the filing of dispositive motions (presently scheduled
for August 1, 2005). In addition, in light of these extensions, the parties hereby jointly request
an adjournment of the October 31, 2005 trial date, until a new date that will permit sufficient
time for any dispositive motions to be briefed and decided before trial.
The parties are seeking these extensions because scheduling conflicts prevented them from
identifying mutually-agreeable dates prior to the close of discovery for the Plaintiffs deposition
and the deposition of several deponents identified by Plaintiff Unfortunately, the parties will be
unable to complete the depositions in this action until late—August due to extensive travel by
Defendant's counsel (Mr. Mazurek) over the next 6 weeks and a trial that Defendant's counsel
must conduct in mid-August. Therefore, the parties respectfully request that the Court extend the
discovery period to September 1, 2005. -
In light of this extension of discovery, the parties also respectfully request an extension of the
deadline for filing of dispositive motions until September 23, 2005. The parties believe that this
new deadline will permit for the potential settlement of this action at the September 9, 2005,
mediation before costs are incurred in connection with briefing dispositive motions. Finally, in
light of the new deadline for dispositive motions, the parties respectfully request that the Court L
adjourn the existing trial date so that dispositive motions may be fully briefed and decided before
the parties incur costs associated with trial preparation, if necessary.
rmmrunn smmsnnu new vnmr cm uewrmx PHILADELPHIA wrrmmawu nmimnmz
sso.z7s.emo zoa.zz4.1a0¤ m.6o9.eaoo smszz.4444 z1s.s79.asoo s¤z.9a4.asu¤ 4w.e5s.a5o¤

Case 1 :04-cv-01374-SLR Document 31 Filed 06/24/2005 Page 2 of 2
The Honorable Sue L. Robinson
June 24, 2005 @CC/-\RTER
P¤g¤ 2 ENG LISH
I have taken the liberty of enclosing a Stipulation/ Form of Order, in the event Your Honor ‘
agrees with this request.
ctfully submitted,
%~ 1%%
Michael P. Kelly P
MPK/mrh
Enclosure
cc: Edward S. Mazurek, Esq.
Noel E. Primos, Esq.
Michael J. Puma, Esq.