Free Letter - District Court of Delaware - Delaware

Case 1 :04-cv-00943-KAJ Document 68 Filed 03/31 /2006 Page 1 of 1
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March 31, 2006
ELECTRONIC FILING via CM/ECF
The Honorable Kent A. Jordan
United States District Court
District of Delaware
844 King Street
Wilmington, Delaware 19801
Re: Dino Petrocelli vi Daimler Chrysler Corp.,
CA. No. 04-943 (KAJ p
Dear Judge Jordan:
Pursuant to the Trial Management Order in the above referenced case, enclosed please
{ind proposed jury instructions submitted by Defendant DaimlerChrysler Corporation.
DairnlerCl1rysler understands the direction of this Court that jury instructions are to be filed as a
joint effort among the parties. Despite DaimlerClirysler’s best efforts, however, it was not able
to confer with pro se plaintiff Dino Petrocelli to get liis input regarding the jury instructions in
time for this filing todayt Counsel for DaimlerChrysler attempted several times to contact Mr,
Petrocelli, but was unsuccessful. Tlrerefore, DaimlerCl1rysler submits these proposed
instructions as a defense—only tiling
Nonetheless, DaimlerChrysler will continue its attempts to confer with Mr. Petroceili and
will tile an amended set of proposed jury instructions, incorporating Mr. Petrocelli’s comments,
as soon as it is able to get those comments,. DairnlerCl1rysler hopes to be able to make such a
submission prior to the final pretrial conference, which is scheduled for Wednesday, April 5,
.2006,
Respectfully,
Sarah E, Dilcuzio
DE Bar LD, 4085
Encl.
cc: Clerk ofthe Court (Electronic tiling via CM/ECP)
Mr. Dino G. Petrocelli (First Class Mail, postage prepaid)