Free Proposed Order - District Court of Delaware - Delaware

Case 1 :04-cv-00961-JJF Document 41 -2 Filed 10/05/2005 Page 1 of 1_
cCarter & Englrsh, LLP
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Wilmington, DE 19899
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WILLIAM F. TAYLOR, JR. fix 3(H984.6399
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ATTORNEYS AT LAW H
October 5, 2005
VIA HAND DELIVERY l
The Honorable Joseph J. Farnan, Jr. I
U.S. District Court for the District of Delaware
844 North King Street .
“ Wilmington, DE 19801 g
Re: Uni-Diversified, Inc. and Triangle Corp. v. Spalding Sports Worldwide, Inc. and
Russell Corporation
U.S. District Court for the District of Delaware, C.A. 04-961 JJF
Our File No.: 99298-00001
Dear Judge Farnan:
Enclosed please find a proposed revised scheduling order for the above captioned case.
By way of brief background, this case was stayed on February 3, 2005, for the purposes of
voluntary mediation before Judge Bifferato. In spite of a full day of mediation, the case did not
settle. The parties have exchanged considerable written discovery and documentation but
numerous depositions still need to be taken. The parties would like to note for the Court that the
schedule proposed in this revised order reflects the truly "international" nature of this case. A .
majority of the conduct (and possible witnesses) occurred in Japan. My primary client is in
Canada and Russell's primary client is in Ireland. Either these parties will travel to the United
States for depositions or the attorneys will travel to them. Either way, we believe the extra time
built into the scheduling order (sixty (60) days) merely reflects the cross border nature of this T
dispute. Both Counsel for the Plaintiff and Defendant jointly request the Court to enter this ‘
revised Order as presented.
Respectfully submitted,
WILLIAM F. TAYLOR, JR.
WFT/jc
Enclosure
Cc: Brad Grout, Esq. r
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