Free Motion to Dismiss - District Court of Delaware - Delaware

Case 1:04-cv-00911-GIVIS Document 115-8 Filed O2/O3/2006 Page 1 0f 2

Case 1 :04-cv-00911-GIVIS Document 115-8 Filed O2/O3/2006 Page 2 of 2
CASARINO, CHRISTMAN & S i~iALt<, P .A.
ATTORNEYS AT LAW
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scc Moana Kino STREET
STEPHEN E. cAsAaWo
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THOMAS E. LEP;
MATTHEW E. o~svRNE _
cHANETA c. BROOKS-MONTOBAN (BU?) 594-4500
JOHN A. MACCONI, ia. EA><; (aan ssa-Asas
October I2, 2005
E. Alred Smith, Esq.
I333 Race Street, Second Floor
Philadelphia, PA l9l07
Re: Kopacz v. DRBA and Craig Sweti
Dear Al:
As you know, we have re—noticed Cathy Kopaciis deposition for October 27, 2005 at 2:00
pm. in my office. I needed to re~notice the deposition within the current discovery cut—off, I
understand that your client when we last spoke was scheduled to undergo a liver transplant. and may
have medical complications which may malte it difhcult, if not impossible, for her to testify at my
office.
I would appreciate it if you would provide medical documentation and any other available
information regarding her status so that we will know how to proceed.
Since her claim for loss of consortium is still a part of this case I will need to get her
deposition at some point. Even if that claim is dismissedi l may still need her testimony if you plan
on calling her as a witness in this case.
Under the circumstances I certainly want to make sure that we proceed in a way that is fair
to your clients, but I do need to mal client.
I look forward to hearing from you. Thm you.
Very ·uly yours,
•l ,;
DONALD M. RANSOM
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