Free Motion to Quash - District Court of Delaware - Delaware

Case 1:04-cv-01304-KAJ

THE NEUBERGER FIRM
ATTORNEYS AND COUNSELLORS AT LAW

Document 72

Filed 03/13/2006

Page 1 of 1

TWO EAST SEVENTH STREET SUITE 302 WILMINGTON, DELAWARE 19801-3707
WWW.NEUBERGERLAW.COM EMAIL: [email protected]

THOMAS S. NEUBERGER, ESQUIRE STEPHEN J. NEUBERGER, ESQUIRE

PHONE: (302) 655-0582 FAX: (302) 655-9329

March 13, 2006 The Honorable Kent A. Jordan United States District Court District of Delaware 844 King Street Wilmington, DE 19801 RE:

Via CM/ECF Filing

EEOC v. P.T. Morgan Paper Company, C.A.No. 04-1304-KAJ Motion to Quash Notice of Deposition

Dear Judge Jordan: The EEOC previously scheduled a deposition for Wednesday, March 23, 2006 at 9:30am. I currently serve on the Third Circuit Lawyer's Advisory Committee. Chief Judge Anthony J. Scirica has scheduled a meeting on that same morning to discuss the upcoming Third Circuit

Judicial Conference, the Model Civil and Criminal Jury Instructions Committees and possible changes to the court rules and internal operating procedures. The EEOC refuses to
reschedule the deposition for this date. Accordingly, I move to quash the scheduled deposition and to reschedule it at a mutually convenient time due to my court obligations. Four depositions are also being taken on March 21st and 22nd which are going forward as planned. Respectfully submitted, /s/ Thomas S. Neuberger Attorney for Defendant cc: Seth M. Beausang, Esq. (Via CM/ECF) M. Jean Clickner, Esq. (Via Email)

PT Morgan \ Letters \ Jordan.04