Free Letter - District Court of Delaware - Delaware

Case 1:04-cv-01304-KAJ

Document 76

Filed 03/15/2006

Page 1 of 1

U.S. EQUAL EMPLOYMENT OPPORTUNITY COMMISSION Philadelphia District Office LEGAL UNIT 21 South 5

Street, Suite 400 Philadelphia, PA 19106-2515 (215) 440-2828 TTY (215) 440-2610 FAX (215) 440-2848

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M. Jean Clickner, SeniorTrial Attorney Direct Dial: (412) 644-6439 Facsimile: (412) 644-4935 E-mail: [email protected]

March 15, 2006 Honorable Kent A. Jordan, U.S.D.J. United States District Court District of Delaware 844 King Street Wilmington, DE 19801 Re: EEOC v. P.T. Morgan Paper Company, an affiliate of P.T. Morgan Packaging Co. Civil Action No. 04-1304

Dear Judge Jordan: While the Commission is sympathetic to Defendant's protestations of an extremely busy schedule, I remind the Court that the deposition at issue here was previously scheduled for a mutually convenient time, only to be postponed by Defendant's motion. However, in an effort to be accommodating, the Commission will agree to permit its Trial Attorney to travel on non-work time, a Sunday, so as to take Mr. Goodermuth's deposition on Monday, April 24, 2006. If the Neuberger Law Firm will make an attorney available at that time, then the issue before the Court will be resolved, for now. The Commission, however, is adamantly opposed to being forced to complete its depositions beyond the close of discovery. The Commission has consistently tried to move forward with its discovery. Mr. Neuberger has blocked off two-and-a-half days for his depositions of the Claimants and the EEOC investigator at the end of discovery. This is not the second, but the third time that he has scheduled the Claimants' depositions. Again, the Commission asks that this Honorable Court rule in favor of the Commission's position in this matter. Very truly yours, /s/ M. Jean Clickner M. Jean Clickner /s/ Seth M. Beausang Seth M. Beausang Thomas S. Neuberger, Esquire (via electronic filing and email)

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