l
From: "Chelyl A. Sasadeusz, Esquire"
To: "JEAN CLICKNER"
Date: 3/7/2006 9:39:35 AM
Subject: Re: EEOC v. PT Morgan Paper - depositions follow up
l
Jean,
Yes, we received your response to our settlement letter. l will be
discussing our options with the client this week.
5
With regard to the depositions, since there doesn't appear to be any reason
for either of us to be filing further summaryjudgment motions, if we both
consent we could arrange for depositions to be taken after the discovery
cut-oif on April 28th. Please let me know if this is a viable option for
you. However, in the event you do not consent, the only three days Tom has
available are April 10, 11 and 12. His calendar is full with trials and
pre-trials throughout March and April.
Let me know what your decision is;
lf you have any questions, please either email or call.
Sincerely, ‘
Cheryl
---— Original Message ——-——
From: "JEAN CLICKNER"
To:
Sent: Tuesday, March 07, 2006 8:57 AM
Subject: Re: EEOC v. PT Morgan Paper — depositions follow up l
> Cheryl, -
>
~ > Is Tom unreachable? Can't you get dates from him this week.
> We will discuss lifting the subpoena when you give me dateslceitain E
> for the Commission's depositions. . §
> i
> In the meantime, l faxed Tom a response to hislyour letter re:
> settlement. §
> Will he be looking at that this week? l
> Thanks. ;
> Jean i
> i
> M. Jean Clickner, Trial Attorney ’
> EEOC Pittsburgh Area Oftice
> (412) 644-6439 §
> (412) 644-4935(fax) · R
> [email protected]
>
>>>> "Cheryl A. Sasadeusz, Esquire"
> 3:29:03 PM >>> ,
> Jean,
"
> Tom is out ofthe office this week. When he returns we will get back to
> you
. · ' - - |4 ·A I• n·| - ·•| ||• '.•· •
l
l
> with dates. In the interim, will you agree to lift the subpoena for Z
> Douglas §
> Goodermuth? lf so, could you put something in writing indicating your l
> intention to lilt the subpoena and send it to us?
> Please let me know of your decision.
> l
> Sincerely,
> Cheryl
> l
. >
> ——-—— Original Message —--——
> From: "JEAN CLICKNER"
> To:
> Sent: Monday, March 06, 2006 8:19 AM
> Subject: Re: EEOC v. PT Morgan Paper — depositions follow up
> e
>> Cheryl, l
>> So as to avoid continued rescheduling, please give me three days in
> a l
>> row that Tom is available.
>> Thanks. -
>> Jean
>>
>> M. Jean Clickner, Trial Attorney
>> EEOC Pittsburgh Area Office
>> (412) 644-6439
>> (412) 644»4935(fax)
>> [email protected]
>> g
>>>>> "Cheiyl A. Sasadeusz, Esquire"
> 3f3!2006
>> 4:45:43 PM >>>
>> Jean -
>>
>> We have just become aware that Tom has been called to an all day ,
>> meeting in the Third Circuit on March 23rd. We previously indicated E
>> today in an email that he would be unavailable on March 21st and
> 22nd. l
>> In light of this, we will have to reschedule your all of your j
> deposition
>> dates for March 21st through March 23rd,
>>
>> Sincerely,
>> Cheryl
>>
>> ~~~~~~~~~~~~~~~
>> Cheryd A. Sasadeusz, Esq. l
>> (Licensed in PA and NJ only)
>> » §
>> The Neuberger Firm, F’.A.
>> Attorneys and Counsellors at Law
>> Two East Seventh Street, Suite 302
>> Wilmington, DE 19801-3707
>> Phone 302.655.05B2
>> Fax 302.655.9329
. · ' - - IA .: I• n·| - ·•| ||• '.•· • I
>> Cell 484.686.8428
>> Email: [email protected]¤m
>> j
>
CC: "Thomas S. Ncubcrgar Esq."
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