`BOUCHARD MARGULES & FRIEBUAGBEROE0000
`Fea)
`SNWie,
`A PROFESSIONAL CORPORATION
`Sue 1400
`Wooton
`Se
`‘i, Cp De Loe
`222 DELAWARE AVENUE
`—
`WILMINGTON, DELAWARE 1980 |
`(302) 573-3500
`FAX (302) 5723-350 |
`
`ANDRE G. BOUCHARD
`JOEL FRIEDLANDER
`Davio J. MARGULES
`
`JOANNE P. PINCKNEY
`COUNSEL
`KAREN L. PASCALE
`JOHN M, SEAMAN
`Dominick T. GaTTUsSO
`
`April 20, 2005
`
`By E-File & Hand Delivery
`
`The Honorable Donald F. Parsons, Jr.
`Court of Chancery
`New Castle County Courthouse
`500 North King Street, Suite 11400
`Wilmington, DE 19801
`
`Re:
`
`American International Group, Inc. Consol. Derivative Litigation, C.A.
`No. 769-N
`
`Dear Vice Chancellor Parsons:
`
`We were retained today to represent individual defendant Maurice R. Greenberg
`in the above-referenced action. Upon being retained, I contacted plaintiffs’ counsel to
`request a one-week extensionoftime to respond to discovery requests that purportedly
`were served on all defendants on March 21, 2005, Plaintiffs’ counsel declined this
`courtesy.
`
`Wehaveserved today objections to the discovery requests. One of our objections
`is that Mr. Greenberg will befiling on Monday, Apri] 25, a motion to dismiss the
`complaint in this action. In view of this imminentfiling, we have filed a motionto stay
`discovery in this action pending the resolution of the motion to dismiss. A courtesy copy
`of our motion to stay discovery is enclosed.
`
`If Your Honorhas any questions concerning any of the above matters, we are
`
`available at the Court’s convenience.
`
`cc:
`
`Register in Chancery (e-file)
`Pamela S. Tikellis, Esquire (e-file)
`
`
`
`EFiled: Apr 20 2005 9:45PM EDT
`Filing ID 5660000
`
`
`
`
`
`The Honorable Donald F. Parsons, Jr.
`Apmil 20, 2005
`Page 2
`
`A. Gilchrist Sparks, II, Esquire (e-file)
`David C. McBride, Esquire (e-file}
`Stephen C. Norman, Esquire (e-file)
`Kurt Heyman, Esquire (e-file)
`Charles M. Oberly, Esquire (e-file)
`Steven I. Froot, Esquire
`
`
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