Case 1:04-cv-01304-KAJ
Document 38-2
Filed 12/12/2005
Page 1 of 1
Jean, I just tried to reach you by phone and left a long m essage. I am vacating the four depositions next W ed. and Thursday. Instead I will m ove for sum m ary judgm ent and file a brief and appendix with a full record on the 15 em ployee issue and aggregation. Please let the four com plainants know. Hopefully that is a m ore econom ical use of m y client's lim ited financial resources. I know it is the Christm as holiday season and I do not necessarily want to squeeze you so we can talk about what is a reasonable briefing schedule once you see m y papers. Tom N. cc: client **************************************** Thom as S. Neuberger, Esquire The Neuberger Firm Attorneys And Counsellors At Law Two East Seventh Street, Suite 302 W ilm ington, Delaware 19801-3707 Phone 302.655.0582 Fax 302.655.9329 Em ail:TSN@ NeubergerLaw.com