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. , ,... <br />LARKIN, HOFFMAN, DALY Bt LINDOREN, LTD. <br />The Hon. Robert B. Danforth <br />May 31, 1995 <br />Page 2 <br />• with Mr. Mac(iibbon about this matter and he indicated that he would not object to a request for a <br />continuance. Therefore, we respectfully request that the trial date be continued and suggest thaj it be <br />scheduled 120 days from the Ciry's motion for summary judgment. This scheduling would allow the <br />coact time to decide the Ciry's summery judgment motion <br />In the attemative, the City objects to the property owner adding witnesses at this late date and will bring a <br />motion to exclude witnesses at the June 9,1995, summaryjudgment motion. In the event that we proceed <br />on Juno l2, 1995, wa request that this case be calendared first on the court's calendar of cases. I believe <br />that the estimate of trial time of one week is reasonable and I will be out of town the week following the <br />week of lone 12. <br />When I spoke to Mr. MacQibbon on May 30 about these issues, we agreed that we would talk with you <br />about the issues in a conference call if you are available. I will call your clerk of find out if you are <br />available to schedule such a call. <br />lartln, foc <br />HOFFMAN, DALY 6t LIND(1REN, Ltd. <br /> <br />~J <br />cc; Clerk of Court <br />John MacClibbon, Esq. <br />Peter K. Beck, Esq. <br />Daniel W. Voss, Esq. <br />oiw:a:.oi <br />Z 'd <br />9£:£I S66S't£'S0 <br />l! H1LI NtlW~jOH NI~IMtlI WOMtl <br />