Free Letter - District Court of Delaware - Delaware

Case 1:04-cv-01211-IVIPT Document 16-4 Filed 11/29/2007 Page 1 013
EXHIBIT C

Case 1:04-cv-01211-IVIPT Document 16-4 Filed 11/29/2007 Page 2 otP§g€ 1 Om
John M. LaRosa, Esguire
From: "Stephen J. Neuberger"
To: "Thomas S. Neuberger" ; "Cheryl Hertzog"
; "John M. LaRosa, Esquire"
Sent: Monday, November 26, 2007 1:03 PM
Subject: FW: Tobin v. Gordon
—---- Original Message -----
From: DiBianca, Margaret [mailto:[email protected]]
Sent: Monday, November 26, 2007 12:49 PM
To: Stephen J. Neuberger
Cc: Bowser, William; kjennings@o 'law.com; [email protected]; Wilson,
Gregg
Subject: Tobin v. Gordon
Good afternoon.
I am writing in regards to the proposed scheduling order you forwarded
before the holiday in the above-referenced matter.
> As you may know, the Defendants filed a Motion to Dismiss, which, in
> part, was based on grounds of qualified immunity in a related matter,
> Jamison v. Gordon. We expect to likely do the same for the Riddell
> and Tobin cases. Due to the qualified immunity issues, we will ask
> the Court to refrain from issuing a scheduling order until those
> motions have been decided.
>
> If you are amenable, Defendants would agree to Judge Thygne's
> jurisdiction if Plaintiff would agree to submit a jointly proposed
> briefing schedule in lieu of the proposed scheduling order.
>
> Please let me know if Plaintiff may be interested in such an
> agreement.
>
> Thank you.
>
> Molly DiBianca
>
> Margaret M. DiBianca, Esq.
> Young Conaway Stargatt & Taylor, LLP
> The Brandywine Building
> 1000 West Street, 17th Floor
> P.O. Box 391
> Wilmington, DE 19899-0391
> Phone: 302-571-5008
> Facsimile: 302-576-3476
> [email protected]
l 1/28/2007

Case 1:04-cv-01211-IVIPT Document 16-4 Filed 11/29/2007 Page 3 oliqége 2 Om
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l 1/28/2007