ADELMAN LAVINE GOLD AND LEVIN
A PROFESSIONAL CORPORATION
ATTORNEYS AND COUNSELORS AT LAW
SUITE 710
919 NORTII MARKET STREET
WILMINGTON, DELAWARE 19801-1292
(302) 654-8200
FACSIMILE (302) 654-8217
lawyers(
July 12’ 2005 ;gii1§t?g%N CENTER
PHILADELPHIA, PA. l9l03—2808
215 568-7515
Via Hand Delivery
The Honorable Joseph J. Faman, Jr.
J. Caleb Boggs Federal Building
844 N. King Street
Room 4124
Wilmington, DE 19801
Re: Interpublic Group of Companies t/a Transworld Marketing Corp.,
. appellant v. Larry Waslow, appellee (In re: M Group, Inc., Bankr. D.
Del. 00-1936-JKF), Civil Action No. 04-353-JJF
Dear Judge Farnan:
This firm represents Larry Waslow (the "Appellee"), who is the Unsecured
Claims Administrator of the bankruptcy estate of M Group, Inc., and the Appellee in the
above-referenced bankruptcy appeal. Upon the suggestion of Your Honor’s Case
Manager, Ms. Deborah Krett, I am writing this letter to Your Honor to inform the Court
that the parties in the above-referenced bankruptcy appeal have reached an agreement in
principle, which is subject to the execution of a mutually acceptable stipulation between
the parties and approval of same pursuant to Federal Rule of Bankruptcy Procedure 9019.
As Your Honor may recall, the Appellant, Interpublic Group of Companies t/a
Transworld Marketing Corp. (the "Appellant"), previously filed its Opening Brief, and
Your Honor’s Order dated July 8, 2005 requires that the Appellee file his Reply Brief on
or before August 8, 2005. In light of the parties reaching a settlement in principle, and on
behalf of both the Appellant and the Appellee, we respectfully request that the briefing
schedule currently in place for this appeal be stayed for at least ninety (90) days so that
the parties have ample opportunity to document, and to obtain Bankruptcy Court
approval of, their proposed settlement.
i` Case 1 :04-cv—00353-JJF Document 16 Filed 07/15/2005 Page 2 of 2
* The Honorable Joseph J. Farnan, Jr.
July 12, 2005
Page 2 of 2
On behalf of the parties, we thank Your Honor for considering this matter.
W Respectfully yours,
. / Bradford J . Sandler
cc: J ami B. Nimeroft] Esquire (counsel for Appellant) (via email
(nimeroff][email protected]) and facsimile (215-665-8760))
Leon R. Barson, Esquire (co—counsel for Appellee) (via email
(lbarsongcbadelmanlaw.com and facsimile (215-557-7922))
Case 1:04-cv-00353-JJF
Document 16
Filed 07/15/2005
Page 1 of 2
Case 1:04-cv-00353-JJF
Document 16
Filed 07/15/2005
Page 2 of 2
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