Wilmington Trust Center; Suite |00 I, I IOO North Market Street, Wilmington, Delaware |980|
Tel: (302) 777-5860 I Fax: (302) 777-5863 I www.Wo|fB|ock.com
Barry M. Klayman
Direct Dial: (302) 777»0313
Direct Fax: (302) 778-7813
E-rnail: bl
August 8, 2005
Via E-Filing and Hand Delivery
The Honorable loseph Farnan, ]r.
U.S. District Court ludge
]. Caleb Boggs Federal Building
844 N. King St.
Room 4124, Lockbox 27
Wilmington, DE 19801
Re: Carole l·lolicl< v. David Oppenheimer and Company
Limited Partnership d/b/a The Oppenheimer Group,
C.A. No. 04-0828 IFF
Dear judge Farnan:
We represent the defendant, David Oppenheimer and Company Limited Partnership, in
the above-referenced matter. Last month the parties requested the Court to refer this matter to
the Magistrate ludge for mediation, which the Court did by Order dated ]uly 25, 2005 (D.l. 23).
Subsequently the Magistrate ludge issued an Order scheduling a teleconference for August 22,
2005 to discuss scheduling of, the procedures involved, and the types of alternative dispute
resolutions available (D.l. 24).
The parties believe that the prospects for a successful mediation would be improved if
they were to defer taking additional discovery until after the mediation efforts. The current
Scheduling Order, however, requires them to complete fact discovery by September 2, 2005.
On behalf of both plaintiff and defendant, I am writing to request the Court to enter a
revised Scheduling Order that would have the effect of postponing the close of fact discovery
until 30 days after the mediation is concluded, and moves back the other deadlines in the
Scheduling Order accordingly. It would also postpone the pretrial conference to a date to be
determined by the Court after notification that the mediation is concluded.
WlL:53398.l/davl59-224216
Boston. MA I Cherry Hi|l,N_| I Harrisburg, PA I New York, NY I Norristown, PA I Philadelphia, PA I Roseland, N] I Wilmington, DE
WolfB|ock Government Relations - Harrisburg, PA I Wo|fBlock Public Strategies - Boston. MA and Washington, DC
V*/coli. Block, Schcrr and Solis-Cohen LLP! a Pennsylvania Limited Liability Partnership
Case 1:04-cv-00828-JJF Document 32 Filed 08/08/2005 Page 2 of 2
The Honorable ]oseph Farnan, ]r.
August 8, ZOO5
Page 2
l am enclosing a proposed form of Order for the Court's convenience. The parties are
available to answer any questions that the Court may have.
Thank you for your consideration of this request.
Rfctfully,
T Barry M. ayman (#3676)
For WOLF, BLOCK, SCHORR and SOLIS»COI·IEN LLP
Enclosure
cc: ]ohn M. LaRosa, Esquire (By ECE Notification)
Thomas S. Neuberger, Esquire (By ECP Notification)
Clerk of the Court (By E»Filing)
]onathan D. Wetchler, Esquire
Paula Zimmerman, Esquire
\X/11.:53398.1/dav159-224216
Case 1:04-cv-00828-JJF
Document 32
Filed 08/08/2005
Page 1 of 2
Case 1:04-cv-00828-JJF
Document 32
Filed 08/08/2005
Page 2 of 2
United States Free Forms
Canada Free Forms
United Kingdom Free Forms
Australia Free Forms