Verance Letter to Judge Brown
June 25, 2001
VIA HAND DELIVERY
Honorable Garrett E. Brown, Jr.
Dear Judge Brown:
I am writing on behalf of defendant Verance Corporation (Verance) in response to Ms. Grayson Barber's June 15, 2001 letter to Magistrate Judge Wolfson in the above-captioned case. I also refer to Mr. David Kendall's letter to you dated June 21, 2001.
As you will note, Mr. Kendall's June 21, 2001 letter included as an attachment my letter to Mr. Gino Scarselli, counsel to plaintiff, dated June 18, 2001. To be clear, in addition to the specific representations I made to Mr. Scarselli in that letter, let me state that Verance will not file any lawsuit over the plaintiffs' papers identified in the complaint. We therefore believe there is no justiciable controversy before the Court with respect to plaintiffs and Verance. Accordingly, we respectfully submit that Ms. Grayson's request for an expedited pleading and discovery schedule is inappropriate and unncessary as to the Verance.
To facilitate your prompt receipt of this letter, I have authorized Ms. Karen A. Confoy, counsel for RIAA, to sign this letter on my behalf.
David E. Leibowitz
Karen A. Confoy
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