Free Letter - District Court of Delaware - Delaware

Case 1:07-cv—00479-SLR-LPS Document 16 Filed 05/09/2008 Page 1 of 2
Majed Subh
204 Latimer Street, Apt. 2
Wilmington, DE 19804
Tel: 302-384-5260
RE: Subh v. Wal-Mart Stores East LP: Civ. No. 07-0479-SLR-LPS
Emergency Motion
May 9, 2008 7,25;
TO: The United States District Court A
District of Delaware I ‘
The Honorable Leonard P. Stark "° I ,,.V
The United States Magistrate Judge
US Courthouse
844 King Street F;. ‘ '
Lock Box 26 U
Wilmington, DE 19801
Re: Subh v. Wal—Mart Stores East LP: Civ. No. 07-0479-SLR-LPS
Dear Honorable Judge Stark:
Due to some health problems I have had inthe last few months, I could not have
enough time to find an attorney to represent my case. I am writing in response to my
scheduled deposition May 6, 2008 at 10 a.m. which has been postponed for one week
by the representative of Wal-Mart which is not enough time for me to continue searching
for an attorney. I am writing also in response to the discovery demands of Wal-Mart
representative in response to the letter from WaI—Mart representative sent on May 6,
2008 which has not been tiled to your honor. —- Attached to this letter and clarifying that
Wal-Mart will have no alternative other than to file a Motion to Compel with the Court if I
don’t respond to their discovery request. Although I explained my emergency situation
for Wal-Mart attorney on the phone, recently on May 8.
I need some time to search for an attorney to represent me and I appreciate your
understanding for my request to postpone my deposition at Wal-Mart representative
office for at least one month and my answer to the discovery request of Wal-Mart.
I am available at the Court’s convenience if your honor has any questions.
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Majed Subh Hf
cc. Wal-Mart representative (hand delivered to their office on May 9, 2008)
Clerk of the Court (hand delivered on May 9, 2008)

Case 1 :07-cv—00479-SLR-LPS Document 16 Filed 05/09/2008 Page 2 of 2
Potter
M Anderson
**¤ COITOOH LLP Sarah E. Dmuzm
Attorney
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Via Federal Express
Mr. Maj ed Subh
204 Latimer Street
Apartment 2
Wilmington, Delaware 19804
Re: Subh v. Wal-Mart Stores East LP, C.A. No. 07-479 - SLR-LPS
Dear Mr. Subh,
I am writing to address your outstanding discovery obligations. As you know,
Wal-Mart served you with its Request For Production Of Documents and First Set Of
Interrogatories on April 2, 2008. I have not received any response to Defendant’s discovery
requests as required by Federal Rules of Civil Procedure 33 and 34. You have failed to comply
with the Court Rules and your discovery responses are now overdue. Please tile and serve your
discovery responses immediately.
Additionally, I am writing to reschedule your deposition, which was postponed as
a result of our telephone discussion on Friday, May 2, 2008, during which you informed me that
you would be unable to appear for your May 6 deposition. I agreed to postpone the deposition
until the week of May 12, 2008, and informed you when we spoke that I would like to take your
deposition May 13, May I5 and/or May 16, 2008. Please let me know immediately which of
these three dates works best for you, and I will tile the appropriate notice with the Court.
It is imperative that I have your responses to Defendant’s Request For Production
Of Documents and First Set Of Interrogatories before your deposition. If you do not
immediately provide your responses to Defendant’s discovery requests, and contact me with the
date for your rescheduled deposition, Wal—Mart will have no altemative other than to file a
Motion to Compel with the Court.
Very truly yours,
Sarah E. DiLuzio /0
863133 /32152