Case 1:04-cv-00193-SLR
Document 139
Filed 06/13/2008
Page 1 of 1
DEPARTMENT OF JUSTICE
JOSEPH R. BIDEN, III
ATTORNEY GENERAL
NEW CASTLE COUNTY 820 NORTH FRENCH STREET WILMINGTON, DELAWARE 19801
CIVIL DIVISION (302) 577-8400 FAX: (302) 577-6630
June 13, 2008 The Honorable Sue L. Robinson. U.S. District Court for the District of Delaware 844 North King Street Wilmington, DE 19801 Mr. Edward McNally, Esq. Mr. Jason Jowers, Esq. Morris James LLP 500 Delaware Ave., Suite 1500 Wilmington, DE 19801 RE: Melendez v. Gardells, et al. , C.A. No. 04-193-SLR
Dear Judge Robinson, Mr. McNally and Mr. Jowers: After deposing the Plaintiff's two fact witnesses this week, Defendants disclose that the following individuals may be called as possible rebuttal witnesses in this case: Lt. Thomas Seacord Captain Michael McCreanor Jeremy McEntire, R.N. Dr. Raman Gopalakrishnan Therefore, Defendants request that the names of these witnesses be included in the proposed voire dire questions to the jury panel, along with Robert Harris, Ron Hosterman, James Scarborough and Cindy Wright (witnesses for the defense), whose names were inadvertently omitted from the parties' joint submission to the Court (D.I.130) on June 3, 2008.
Respectfully submitted, /s/Catherine Damavandi Catherine Damavandi, I.D. #3823