Free Letter - District Court of Delaware - Delaware

Case 1:07-cv-00717-SLR Document 18 Filed O1/18/2008 Page 1 of 1
BIGGS AND BATTAGLIA
vrcron B. BATTAGLIA ATTORNEYS AT LAW. gp COUNSEL
ROBERT D. c;oLDBB1zc 921 NORTH ORANGE STREET ]oHN BIGGS III
1>1111.11> B. BARTOSHESKY RO- EOX 1*189 · GBRARD B. 1 vrcron B. BArrAc1.1A,]R. . WR~M1NOTON» DELAWARE 19899 s. BERNARD ABLEMAN
(302) 655-9677
TBLBco1¤1BR (502) 655-7924
Writer's Direct E-mail: [email protected]
‘ January 18, 2008
Via E-File I
The Honorable Mary Pat Thynge
c/o United States District Court
844 King Street
Lock Box 8
Wilmington, DE 19801
Re: International Brotherhood of Electrical Workers Local 98 Pension Fund V.
Angelo R. Mozilo, et. al., CA No. 07 -— 00372 ""‘°* (MPT)
T Adam Blumberg v. Angelo R. Mozilo, et. al. CA No. 07 - 00717 *** (MPT)
Dear Judge Thynge:
R Plaintiffs are in receipt of the letter filed by Mr. Pineman and his accompanying
I . Motion requesting that this Court enter an Order Staying Plaintiffs’ Motion for Partial
1 Summary Judgment in the above two matters. Mr. Pineman also requests that the Court
l convene a telephone conference at your Honor’s earliest convenience.
On behalf of Plaintiffs, we intend to respond to the Motion and expect to have our
papers to the Court by end of business Tuesday, February 22, 2008. We ask that the
Court schedule any conference thereafter. Further, because of the complexity of the
y issues involved, we believe that an in person conference would be more helpful to the
1 Court in understanding the issues involved and the parties} positions on them.
Accordingly, Plaintiffs respectfully request an in person conference with the Court to
discuss the issues raised.
l We are available at the Court’s convenience.
l Respectfully submitted,
h
` Robert D. Go erg
RDG/rc
cc: Edward Micheletti, Esquire
l Steven J. Fineman, Esquire

Case 1:07-cv-00717-SLR

Document 18

Filed 01/18/2008

Page 1 of 1