Free Proposed Order - District Court of Delaware - Delaware

Case 1 :04-cv-00961-JJF Document 46-2 Filed 03/21 /2006 Page 1 of 1_ I
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ATTORNEYS AT LAW _
March 21, 2006 L`.
VIA HAND DELIVERY ~
The Honorable Joseph J. Farnan, Jr.
U.S. District Court for the District of Delaware
844 North King Street ..
Wihnington, DE 19801 —.
Re: Uni-Diversified, Inc. and Triangle Corp. v. Spalding Sports Worldwide, Inc. and Z
Russell Corporation
- U.S. District Court for the District of Delaware, C.A. 04-961 JJF
Our File No.: 99298-00001 _
Dear Judge Farnan: y
The parties in this case have all but completed discovery, except for the taking of
depositions. We were delayed in that task due to the rather extraordinary efforts both sides have
employed attempting settlement of this case. Quite hankly, we have been in ongoing and ‘
extensive settlement discussions for months. Unfortunately, and not from any lack of effort, we ;
cannot come to a resolution acceptable to both sides. As such, the parties need to take
depositions and prepare this case for trial. The parties mutually believe that the modest additional J
time sought in the attached "Stipulated Proposed Second Amended Rule 16 Scheduling Order" is
A needed to finish out the discovery and prepare the case for trial. I ij;
Should the Court have any comments or concerns, the parties will make themselves
_ available to discuss at the Court's convenience.
Respectfully submitted, l
WILLIAM F. TAYLOR, JR.
WFT/jc I
Enclosure
Cc: Brad Grout, Esq. ` ‘_
Larry Bracken, Esq. .
Michael A. Weidinger, Esq. i
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