Free Response to Motion - District Court of Delaware - Delaware

Case 1:04-cv-00705-JJF

Document 44-3
LAW OFFICES

Filed 04/27/2006

Page 1 of 1

PARKOWSKI, GUERKE & SWAYZE
PROFESSIONAL ASSOCIATION 800 KING STREET, SUITE 203 WILMINGTON, DELAWARE 19801 302-654-3300 FAX: 302-654-3033
GEORGE F. GARDNER, III
OF COUNSEL

F. MICHAEL PARKOWSKI I. BARRY GUERKE DAVID S. SWAYZE CLAY T. JESTER JEREMY W. HOMER JOHN C. ANDRADE MARK F. DUNKLE WILLIAM A. DENMAN MICHAEL W. ARRINGTON CHRISTINE P. SCHILTZ MICHAEL W. TEICHMAN BASIL C. KOLLIAS ANNE HARTNETT REIGLE

WRITER'S DIRECT DIAL: (302) 594-3333

DOVER OFFICE 116 W. WATER STREET PO BOX 598 DOVER, DE 19903-0598 302-678-3262 FAX: 302-678-9415

November 1, 2004

James M. Kamara 164 S. Main Street Smyrna, DE 19977 RE: Kamara v. Michael Funding, LLC Civil Action No. 04-705 (JJF)

Dear Mr. Kamara: Your requests for production of documents and your handwritten edits to the draft scheduling order were received this morning. The scheduling order was sent to the Court on October 20, 2004 in the absence of any response from you. We are not agreeable to extending the timeframes. Your request for production of documents does not conform with the Court rules and we will not be providing any response to you until a proper document is served. As we discussed last week, you have yet to provide the required Rule 26(a) initial disclosures. Further, you are aware that the loan in question was a commercial loan not subject to any of the laws upon which you rely. We will allow you until November 8, 2004, to return the enclosed stipulation of dismissal signed by you for filing with the Court. If you choose to proceed, we will be seeking attorneys fees and costs in the range of $4,000.00. We await your reply. Yours very truly,

MICHAEL W. ARRINGTON
MWA:s Enclosure cc: Michael Funding, LLC
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