Free Letter - District Court of Delaware - Delaware

Case 1:04-cv-00339-JJF

Document 174

Filed 12/09/2005

Page 1 of 2

1800 One Liberty Place Philadelphia, PA 19103-7395 Phone: 215.864.7000 Fax: 215.864.7123

Ron L. Pingitore Direct Dial: 215.864.6324 Direct Fax: 215.789.7504 [email protected]

December 9, 2005
VIA E-FILE AND REGULAR MAIL

The Honorable Joseph J. Farnan, Jr. United States District Court District of Delaware 844 N. King Street, Room 4124 Wilmington, DE 19801 Re: Federal Insurance Company v. Lighthouse Construction Millers Capital Insurance Co. v. Lighthouse Construction Factory Mutual Insurance Co. v. Lighthouse Construction Civil Action Nos. 04-339; 04-1322; and 05-96 Dear Judge Farnan: Plaintiffs participated in a mediation with East Coast Erectors, Inc. and Becker Morgan Group yesterday. Magistrate Judge Thynge conducted the mediation. As a result, plaintiffs reached an agreement in principal to settle with each defendant and are endeavoring to draft the release agreements. The settlement leaves O'Donnell, Naccarratto & MacIntosh, Inc. ("ONM") as the sole defendant. Plaintiffs previously settled with Lighthouse Construction, Inc. The purpose of this letter is to request, on behalf of the settling parties, the Court's indulgence in extending the deadline for filing dispositive motions. The scheduling orders require that Case Dispositive Motions be filed on or before December 16, 2005. The settling parties are requesting that the date be extended for two weeks (through 12/30/05)to allow for the finalization of the agreements reached yesterday. This request does not include extending the deadline on behalf of ONM. That date, under this request, would remain December 16, 2005.

Allentown, PA · Cherry Hill, NJ · New York, NY · Paoli, PA Paramus, NJ · Philadelphia, PA · Pittsburgh, PA · Wilmington, DE
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Case 1:04-cv-00339-JJF

Document 174

Filed 12/09/2005

Page 2 of 2

The Honorable Joseph J. Farnan, Jr. December 9, 2005 Page 2

The settling parties would also request that the Court hold all pending motions in abeyance to allow for the finalization of the settlement agreements. Thank you. Very truly yours, WHITE AND WILLIAMS LLP

By: Ron L. Pingitore, Esquire RLP:teb cc: The Honorable Mary Pat Thynge (via e-mail) All Counsel via Fax

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