Preview
IN THE COURT OF COMMON PLEAS OF DELAWARE COUNTY,
COVER SHEET - NOTICE OF FILING OF MOTION OR PETITION UNDER
LOCAL RULES OF CIVIL PROCEDURE
Gloria Salaam Court of Common Pleas
Delaware County
v.
Natisha Knox
CV-2021-001929
NATURE OF MATTER FILED: (please check one)
__ Petition Pursuant to Rule 206.1 __ Response to Petition Motion for Judgment on the
Pleadings Pursuant to Rule 1034(a)
X_ Motion Pursuant to Rule 208.1 __ Response to Motion Summary Judgment
Pursuant to Rule 1035.2
__ Family Law Petition/Motion Pursuant to Rule 206.8
FILING PARTY IS RESPONSIBLE FOR SERVICE OF THE RULE RETURNABLE
DATE OR HEARING DATE UPON ALL PARTIES
A motion or petition was filed in the above-captioned matter on which:
Requires you, Respondent, to file an Answer within twenty (20) days of the above date of this
notice, or risk the entry of an Order in favor of the Petitioner. Answers must be filed and time
stamped by the Office of Judicial Support by 4:30 p.m. on the following date:
Requires all parties, to appear at a hearing on at in
Courtroom , Delaware County Courthouse, Media, Pennsylvania. At this
hearing/conference you must be prepared to present all testimony and/or argument, and must
ensure that your witnesses be present.
Was timely answered, thus requiring the scheduling of the following hearing in the above-
captioned matter on: at a.m. in Courtroom
At this hearing, all parties must be prepared to present all testimony and/or argument and ‘must
ensure that their witnesses will be present.
Qualifies as an Uncontested Motion or Petition, and, as such, requires neither an answer from
the Respondent nor the scheduling of a hearing in this matter.
Has been assigned to Judge
FOR OFFICE USE ONLY:
Mailing Date: Processed By:
Gloria Salaam Court of Common Pleas
Delaware County
V.
Natisha Knox
CV-2021-001929
ORDER
AND NOW, this day of ,20 , upon consideration of the Defendant's
Motion to Compel Responses to Discovery Requests Addressed to Plaintiff, Gloria Salaam, it is
hereby ORDERED that the Plaintiff shall provide complete and verified answers to Defendant's
Interrogatories and complete responses to Request for Production of Documents within twenty
(20) days of the date of this Order or risk sanctions as may be appropriate.
BY THE COURT:
Hubshman, Flood, Dorn, Kolb & Schweikert
By: Katie E. Barbetta, Esquire
Attorney ID #317807
5165 Campus Drive, Suite 200 Attorney for Defendant
Plymouth Meeting, PA 19462 Natasha D. Knox
Telephone #(610) 276-4984
Our File #192631704-001
Gloria Salaam Court of Common Pleas
Delaware County
V.
Natisha Knox
CV-2021-001929
DEFENDANT, NATASHA KNOX’S, MOTION TO COMPEL PLAINTIFF'S, GLORIA
SALAAM, RESPONSES TO DISCOVERY REQUESTS
Defendant moves this Honorable Court to enter an Order pursuant to Pa. R.C.P. 4019
compelling Plaintiff, Gloria Salaam, to answer certain discovery propounded upon them by
Defendant in this matter. In support of this motion, Defendant aver the following:
1 On 3/26/21, Defendant served Plaintiff's counsel Interrogatories and Request for
Production of Documents to be answered within thirty (30) days. See Exhibit “A” attached
hereto.
2 On 5/3/21, counsel for Defendant sent correspondence to Plaintiff's counsel in
follow up to the initial request. See Exhibit “B” attached hereto.
3 As of this date, Plaintiff has not fully answered these Interrogatories or Request
for Production of Documents, which is in violation of the Pennsylvania Rules of Civil Procedure.
4 The said Interrogatories are relevant, material and necessary and Defendant will
be prejudiced if full and complete Answers to the Interrogatories are not filed.
5 If Plaintiffdo not provide the information requested in the Request for Production
of Documents, Defendant will be severely prejudiced in the defense of this case. The said
Request for Production of Documents are relevant, material and necessary to the defense of this
case
6. Plaintiff's counsel has not provided responses.
WHEREFORE, it is respectfully requested that this Honorable Court enter an Order
directing Plaintiff to file full, complete and specific Answers to Interrogatories and Request for
Production of Documents.
Hubshman, Flood, Dorn, Kolb & Schweikert
Kati Bacbetia.
Katie E. Barbetta, Esquire
Attorney for Defendant
Hubshman, Flood, Dorn, Kolb & Schweikert
By: Katie E. Barbetta, Esquire
Attorney ID #317807
5165 Campus Drive, Suite 200 Attorney for Defendant
Plymouth Meeting, PA 19462 Natasha D. Knox
Telephone #(610) 276-4984
Our File #192631704-001
Gloria Salaam Court of Common Pleas
Delaware County
V.
Natisha Knox
CV-2021-001929
DEFENDANT'S MEMORANDUM OF LAW IN SUPPORT OF MOTION TO COMPEL
PLAINTIFF'S, GLORIA SALAAM, RESPONSES TO DISCOVERY REQUESTS
1 Matter before the Court: Before the Court is Defendant's Motion to Compel
Discovery in the form of a Motion to Compel Answers to Interrogatories and Request for
Production of Documents.
2 Statement of Question Involved: Are Defendant entitled to an Order compelling
Plaintiff to answer Interrogatories and Request for Production of Documents where
Interrogatories and Request for Production of Documents were forwarded more than thirty (30)
days ago and are now overdue?
Suggested answer: Yes
3 Facts: On 3/26/21, Defendant's counsel served Interrogatories and Request for
Production of Documents on counsel for Plaintiff. More than thirty (30) days have now elapsed
and Plaintiff have failed to respond to the requested discovery.
4 Argument: Pa. R.C.P. 4005, titled, Written Interrogatories to a party permits one
party to serve any other party with written interrogatories. Pa. R.C.P. 4006 requires a party to
provide written, verified interrogatories within thirty (30) days after service of the
interrogatories.
Pa. R.C.P. 4009.1, titled, Production of Documents and Things, permits a party to serve
or request upon any party to produce designated documents, including writings, drawings, grafts,
charts, photographs, electronically created data, and other compilations of data from which
information can be obtained. Pa. R.C.P. 4009.12 provides that a party shall respond to said
request within thirty (30) days.
Thirty days have now elapsed since Defendant forwarded Interrogatories and Request for
Production of Documents to Plaintiff
and they have failed to respond or otherwise object to these
discovery requests.
5 Relief: Wherefore, Defendant respectfully requests this Court grant the Motion
and issue an Order compelling Plaintiff to respond to Defendant's discovery requests within
twenty (20) days.
Hubshman, Flood, Dorn, Kolb & Schweikert
Kate lo Bubetta
Katie E. Barbetta, Esquire
Attorney for Defendant
Hubshman, Flood, Dorn, Kolb & Schweikert
By: Katie E. Barbetta, Esquire
Attorney ID #317807
5165 Campus Drive, Suite 200 Attorney for Defendant
Plymouth Meeting, PA 19462 Natasha D. Knox
Telephone #(610) 276-4984
Our File #192631704-001
Gloria Salaam Court of Common Pleas
Delaware County
V.
Natisha Knox
CV-2021-001929
CERTIFICATE OF SERVICE
I, Katie E. Barbetta, attorney for Defendant, hereby certify that I caused a true and correct
copy of Motion to Compel Responses to Discovery Requests and Memorandum of Law in Support
of the same to be sent via United States, postage prepaid, first class mail to the following:
Joel J. Kofsky, Esquire
Law Offices Of Joel J. Kofsky, P.C.
Two Penn Center Plaza
1500 JFK Boulevard, Suite 550
Philadelphia, PA 19102
(215) 735-4800/(215) 735-7919 (F)
Hubshman, Flood, Dorn, Kolb & Schweikert
Kati Bacbetia.
Katie E. Barbetta, Esquire
Attorney for Defendant
Date: June 4, 2021
Hubshman, Flood, Dorn, Kolb & Schweikert
By: Katie E. Barbetta, Esquire Attorney for Defendant,
Attorney ID #317807 Natasha D. Knox
5165 Campus Drive, Suite 200
Plymouth Meeting, PA 19462
Telephone #(610) 276-4984
Our File #192631704-001
Gloria Salaam Court of Common Pleas
Delaware County
V.
Natisha Knox
CV-2021-001929
CERTIFICATE OF COMPLIANCE
I, Katie E. Barbetta, attorney for Defendant, Natasha D. Knox, hereby certify that this filing
complies with the provisions of the Public Access Policy of the Unified Judicial System of
Pennsylvania: Case Records of the Appellate and Trial Courts that require filing confidential
information and documents differently than non-confidential information and documents.
Hubshman, Flood, Dorn, Kolb & Schweikert
Kati Bacbetia.
Katie E. Barbetta, Esquire
Attorney for Defendant
VERIFICATION
I, Katie E. Barbetta, Esquire, aver that I am the attorney for the Defendant in this case,
and | aver that the averments contained in the foregoing pleadings are true and correct to the best
of my knowledge, information and belief; and that the statements therein are made subject to the
penalties of 18 Pa.C.S. Section 4904 relating to unsworn falsification to authorities.
Kata
6 Earbette,
Katie E. Barbetta, Esquire
Gloria Salaam Court of Common Pleas
Delaware County
V.
Natisha Knox
CV-2021-001929
ATTORNEY CERTIFICATION OF GOOD FAITH
Pursuant to Delaware County Local R.C.P. 208.2(e)
The undersigned counsel for movant hereby certifies and attests that:
x a) Defense counsel has had the contacts described below with opposing
counsel or unrepresented party regarding the discovery matter contained in the foregoing
discovery motion in an effort to resolve the specific discovery dispute(s) at issue and, further,
that despite all counsel’s good faith attempts to resolve the dispute(s), counsel have been unable
to do so.
Description: On 3/26/21, Interrogatories and Request for Production of Documents
were served upon Plaintiff in accordance with the applicable rules of civil procedure and the
Plaintiffhas not responded. .On 5/3/21, a ten day letter was sent to counsel requesting discovery
responses.
b). He or she has made a good faith but unsuccessful efforts described below to
contact opposing counsel or unrepresented party in an effort to resolve the discovery dispute.
Description:
CERTIFIED TO THE COURT BY:
Kati Bacbetia.
Katie E. Barbetta, Esquire
Attorney for Defendant
QO
re
9
cows
HUBSHMAN, FLOOD, DORN, KOLB & SCHWEIKERT
Not a Partnership, Not a Corporation
SALARIED EMPLOYEES OF PROGRESSIVE
CASUALTY INSURANCE COMPANY
5165 CAMPUS DRIVE, SUITE 200
PLYMOUTH MEETING, PA 19462
Katie E. Barbetta, Esquire Legal Assistant: Justin L. Garzone
Direct #(610) 276-4984 Direct# (610) 276-4834
Facsimile #(866) 842-1482 justin_garzone@progressive.com
KATIE_E_ BARBETTA@progressive.com
March 26, 2021
Joel J. Kofsky, Esquire
Two Penn Center Plaza
1500 JFK Boulevard, Suite 550
Philadelphia, PA 19102
RE: Salaam v. Knox
Delaware County Court of Common Pleas Nos CV-2021-001929
File No. 192631704-001
Dear Mr. Kofsky:
I represent the Defendant, Natasha D. Knox, in the above-captioned matter. Enclosed
please find the following:
Interrogatories Addressed to Plaintiff(s);
Request for Production Addressed to Plaintiff(s); and
Notice of Deposition.
Tam in the process of preparing a Response to your Complaint, and I anticipate that I will
need an extension to file a responsive pleading. Unless I hear from you to the contrary, I will
assume that you have no objection to such an extension.
If you served any documents on my client, please provide me with a copy. This
would include any Discovery Requests or Requests for Admissions. Unless I am provided
with a copy of the Discovery Requests or Requests for Admissions, it will be assumed they
have not been served.
It is the goal of this office to expedite the resolution of litigation against my clients in an
efficient manner by scheduling depositions early in the discovery process. With notice well in
advance, I believe that scheduling conflicts can be easily recognized and avoided. Enclosed is a
Notice of Deposition directed to your client to take place on June 17, 2021 at 10:00 a.m. at Via
Microsoft Teams. | will provide a court reporter at that time. If you would like to depose my
client at the same time, kindly provide me with a Notice of Deposition. If this date is
inconvenient, please contact my office to reschedule the deposition for another date, within fourteen
(14) days. If I do not hear from you within fourteen (14) days of the date of this letter, I will assume
that you are agreeable with the date of the deposition and we will proceed on that date.
Thank you for your anticipated professional courtesies.
Very truly yours,
Kata
6 Earbette,
Katie E. Barbetta, Esquire
KEB/jah
Enclosure
QO
re
9
cows
HUBSHMAN, FLOOD, DORN, KOLB & SCHWEIKERT
Not a Partnership, Not a Corporation
SALARIED EMPLOYEES OF PROGRESSIVE
CASUALTY INSURANCE COMPANY
5165 CAMPUS DRIVE, SUITE 200
PLYMOUTH MEETING, PA 19462
Katie E. Barbetta, Esquire Legal Assistant: Justin L. Garzone
Direct #(610) 276-4984 Direct# (610) 276-4834
Facsimile #(866) 842-1482 justin_garzone@progressive.com
KATIE_E_ BARBETTA@progressive.com
May 3, 2021
Via Email
Joel J. Kofsky, Esquire
Law Offices Of Joel J. Kofsky, P.C.
Two Penn Center Plaza
1500 JFK Boulevard, Suite 550
Philadelphia, PA 19102
RE: Salaam v. Knox
Delaware County Court of Common Pleas No. CV-2021-001929
File No. 192631704-001
Dear Counsel:
Please allow this correspondence to serve as a follow-up to my previous letter wherein I
enclosed Interrogatories and a Request for Production of Documents addressed to your client.
To date, I have not received your client’s responses.
Please forward your client’s discovery responses within ten days from the date of this
letter, or I will file a Motion to Compel.
Thank you for your anticipated cooperation with regard to this matter.
Very truly yours,
Galli Haron?
Jillian Hansberry, Administrative Assistant to
Katie E. Barbetta, Esquire
KEB/jah
FILED
06-04-2021 10:07 AM
OFFICE‘LAWARE
OF JUDICIAL SUPPORT
COUNTY,
Preview
IN THE COURT OF COMMON PLEAS OF DELAWARE COUNTY, COVER SHEET - NOTICE OF FILING OF MOTION OR PETITION UNDER LOCAL RULES OF CIVIL PROCEDURE Gloria Salaam Court of Common Pleas Delaware County v. Natisha Knox CV-2021-001929 NATURE OF MATTER FILED: (please check one) __ Petition Pursuant to Rule 206.1 __ Response to Petition Motion for Judgment on the Pleadings Pursuant to Rule 1034(a) X_ Motion Pursuant to Rule 208.1 __ Response to Motion Summary Judgment Pursuant to Rule 1035.2 __ Family Law Petition/Motion Pursuant to Rule 206.8 FILING PARTY IS RESPONSIBLE FOR SERVICE OF THE RULE RETURNABLE DATE OR HEARING DATE UPON ALL PARTIES A motion or petition was filed in the above-captioned matter on which: Requires you, Respondent, to file an Answer within twenty (20) days of the above date of this notice, or risk the entry of an Order in favor of the Petitioner. Answers must be filed and time stamped by the Office of Judicial Support by 4:30 p.m. on the following date: Requires all parties, to appear at a hearing on at in Courtroom , Delaware County Courthouse, Media, Pennsylvania. At this hearing/conference you must be prepared to present all testimony and/or argument, and must ensure that your witnesses be present. Was timely answered, thus requiring the scheduling of the following hearing in the above- captioned matter on: at a.m. in Courtroom At this hearing, all parties must be prepared to present all testimony and/or argument and ‘must ensure that their witnesses will be present. Qualifies as an Uncontested Motion or Petition, and, as such, requires neither an answer from the Respondent nor the scheduling of a hearing in this matter. Has been assigned to Judge FOR OFFICE USE ONLY: Mailing Date: Processed By: Gloria Salaam Court of Common Pleas Delaware County V. Natisha Knox CV-2021-001929 ORDER AND NOW, this day of ,20 , upon consideration of the Defendant's Motion to Compel Responses to Discovery Requests Addressed to Plaintiff, Gloria Salaam, it is hereby ORDERED that the Plaintiff shall provide complete and verified answers to Defendant's Interrogatories and complete responses to Request for Production of Documents within twenty (20) days of the date of this Order or risk sanctions as may be appropriate. BY THE COURT: Hubshman, Flood, Dorn, Kolb & Schweikert By: Katie E. Barbetta, Esquire Attorney ID #317807 5165 Campus Drive, Suite 200 Attorney for Defendant Plymouth Meeting, PA 19462 Natasha D. Knox Telephone #(610) 276-4984 Our File #192631704-001 Gloria Salaam Court of Common Pleas Delaware County V. Natisha Knox CV-2021-001929 DEFENDANT, NATASHA KNOX’S, MOTION TO COMPEL PLAINTIFF'S, GLORIA SALAAM, RESPONSES TO DISCOVERY REQUESTS Defendant moves this Honorable Court to enter an Order pursuant to Pa. R.C.P. 4019 compelling Plaintiff, Gloria Salaam, to answer certain discovery propounded upon them by Defendant in this matter. In support of this motion, Defendant aver the following: 1 On 3/26/21, Defendant served Plaintiff's counsel Interrogatories and Request for Production of Documents to be answered within thirty (30) days. See Exhibit “A” attached hereto. 2 On 5/3/21, counsel for Defendant sent correspondence to Plaintiff's counsel in follow up to the initial request. See Exhibit “B” attached hereto. 3 As of this date, Plaintiff has not fully answered these Interrogatories or Request for Production of Documents, which is in violation of the Pennsylvania Rules of Civil Procedure. 4 The said Interrogatories are relevant, material and necessary and Defendant will be prejudiced if full and complete Answers to the Interrogatories are not filed. 5 If Plaintiffdo not provide the information requested in the Request for Production of Documents, Defendant will be severely prejudiced in the defense of this case. The said Request for Production of Documents are relevant, material and necessary to the defense of this case 6. Plaintiff's counsel has not provided responses. WHEREFORE, it is respectfully requested that this Honorable Court enter an Order directing Plaintiff to file full, complete and specific Answers to Interrogatories and Request for Production of Documents. Hubshman, Flood, Dorn, Kolb & Schweikert Kati Bacbetia. Katie E. Barbetta, Esquire Attorney for Defendant Hubshman, Flood, Dorn, Kolb & Schweikert By: Katie E. Barbetta, Esquire Attorney ID #317807 5165 Campus Drive, Suite 200 Attorney for Defendant Plymouth Meeting, PA 19462 Natasha D. Knox Telephone #(610) 276-4984 Our File #192631704-001 Gloria Salaam Court of Common Pleas Delaware County V. Natisha Knox CV-2021-001929 DEFENDANT'S MEMORANDUM OF LAW IN SUPPORT OF MOTION TO COMPEL PLAINTIFF'S, GLORIA SALAAM, RESPONSES TO DISCOVERY REQUESTS 1 Matter before the Court: Before the Court is Defendant's Motion to Compel Discovery in the form of a Motion to Compel Answers to Interrogatories and Request for Production of Documents. 2 Statement of Question Involved: Are Defendant entitled to an Order compelling Plaintiff to answer Interrogatories and Request for Production of Documents where Interrogatories and Request for Production of Documents were forwarded more than thirty (30) days ago and are now overdue? Suggested answer: Yes 3 Facts: On 3/26/21, Defendant's counsel served Interrogatories and Request for Production of Documents on counsel for Plaintiff. More than thirty (30) days have now elapsed and Plaintiff have failed to respond to the requested discovery. 4 Argument: Pa. R.C.P. 4005, titled, Written Interrogatories to a party permits one party to serve any other party with written interrogatories. Pa. R.C.P. 4006 requires a party to provide written, verified interrogatories within thirty (30) days after service of the interrogatories. Pa. R.C.P. 4009.1, titled, Production of Documents and Things, permits a party to serve or request upon any party to produce designated documents, including writings, drawings, grafts, charts, photographs, electronically created data, and other compilations of data from which information can be obtained. Pa. R.C.P. 4009.12 provides that a party shall respond to said request within thirty (30) days. Thirty days have now elapsed since Defendant forwarded Interrogatories and Request for Production of Documents to Plaintiff and they have failed to respond or otherwise object to these discovery requests. 5 Relief: Wherefore, Defendant respectfully requests this Court grant the Motion and issue an Order compelling Plaintiff to respond to Defendant's discovery requests within twenty (20) days. Hubshman, Flood, Dorn, Kolb & Schweikert Kate lo Bubetta Katie E. Barbetta, Esquire Attorney for Defendant Hubshman, Flood, Dorn, Kolb & Schweikert By: Katie E. Barbetta, Esquire Attorney ID #317807 5165 Campus Drive, Suite 200 Attorney for Defendant Plymouth Meeting, PA 19462 Natasha D. Knox Telephone #(610) 276-4984 Our File #192631704-001 Gloria Salaam Court of Common Pleas Delaware County V. Natisha Knox CV-2021-001929 CERTIFICATE OF SERVICE I, Katie E. Barbetta, attorney for Defendant, hereby certify that I caused a true and correct copy of Motion to Compel Responses to Discovery Requests and Memorandum of Law in Support of the same to be sent via United States, postage prepaid, first class mail to the following: Joel J. Kofsky, Esquire Law Offices Of Joel J. Kofsky, P.C. Two Penn Center Plaza 1500 JFK Boulevard, Suite 550 Philadelphia, PA 19102 (215) 735-4800/(215) 735-7919 (F) Hubshman, Flood, Dorn, Kolb & Schweikert Kati Bacbetia. Katie E. Barbetta, Esquire Attorney for Defendant Date: June 4, 2021 Hubshman, Flood, Dorn, Kolb & Schweikert By: Katie E. Barbetta, Esquire Attorney for Defendant, Attorney ID #317807 Natasha D. Knox 5165 Campus Drive, Suite 200 Plymouth Meeting, PA 19462 Telephone #(610) 276-4984 Our File #192631704-001 Gloria Salaam Court of Common Pleas Delaware County V. Natisha Knox CV-2021-001929 CERTIFICATE OF COMPLIANCE I, Katie E. Barbetta, attorney for Defendant, Natasha D. Knox, hereby certify that this filing complies with the provisions of the Public Access Policy of the Unified Judicial System of Pennsylvania: Case Records of the Appellate and Trial Courts that require filing confidential information and documents differently than non-confidential information and documents. Hubshman, Flood, Dorn, Kolb & Schweikert Kati Bacbetia. Katie E. Barbetta, Esquire Attorney for Defendant VERIFICATION I, Katie E. Barbetta, Esquire, aver that I am the attorney for the Defendant in this case, and | aver that the averments contained in the foregoing pleadings are true and correct to the best of my knowledge, information and belief; and that the statements therein are made subject to the penalties of 18 Pa.C.S. Section 4904 relating to unsworn falsification to authorities. Kata 6 Earbette, Katie E. Barbetta, Esquire Gloria Salaam Court of Common Pleas Delaware County V. Natisha Knox CV-2021-001929 ATTORNEY CERTIFICATION OF GOOD FAITH Pursuant to Delaware County Local R.C.P. 208.2(e) The undersigned counsel for movant hereby certifies and attests that: x a) Defense counsel has had the contacts described below with opposing counsel or unrepresented party regarding the discovery matter contained in the foregoing discovery motion in an effort to resolve the specific discovery dispute(s) at issue and, further, that despite all counsel’s good faith attempts to resolve the dispute(s), counsel have been unable to do so. Description: On 3/26/21, Interrogatories and Request for Production of Documents were served upon Plaintiff in accordance with the applicable rules of civil procedure and the Plaintiffhas not responded. .On 5/3/21, a ten day letter was sent to counsel requesting discovery responses. b). He or she has made a good faith but unsuccessful efforts described below to contact opposing counsel or unrepresented party in an effort to resolve the discovery dispute. Description: CERTIFIED TO THE COURT BY: Kati Bacbetia. Katie E. Barbetta, Esquire Attorney for Defendant QO re 9 cows HUBSHMAN, FLOOD, DORN, KOLB & SCHWEIKERT Not a Partnership, Not a Corporation SALARIED EMPLOYEES OF PROGRESSIVE CASUALTY INSURANCE COMPANY 5165 CAMPUS DRIVE, SUITE 200 PLYMOUTH MEETING, PA 19462 Katie E. Barbetta, Esquire Legal Assistant: Justin L. Garzone Direct #(610) 276-4984 Direct# (610) 276-4834 Facsimile #(866) 842-1482 justin_garzone@progressive.com KATIE_E_ BARBETTA@progressive.com March 26, 2021 Joel J. Kofsky, Esquire Two Penn Center Plaza 1500 JFK Boulevard, Suite 550 Philadelphia, PA 19102 RE: Salaam v. Knox Delaware County Court of Common Pleas Nos CV-2021-001929 File No. 192631704-001 Dear Mr. Kofsky: I represent the Defendant, Natasha D. Knox, in the above-captioned matter. Enclosed please find the following: Interrogatories Addressed to Plaintiff(s); Request for Production Addressed to Plaintiff(s); and Notice of Deposition. Tam in the process of preparing a Response to your Complaint, and I anticipate that I will need an extension to file a responsive pleading. Unless I hear from you to the contrary, I will assume that you have no objection to such an extension. If you served any documents on my client, please provide me with a copy. This would include any Discovery Requests or Requests for Admissions. Unless I am provided with a copy of the Discovery Requests or Requests for Admissions, it will be assumed they have not been served. It is the goal of this office to expedite the resolution of litigation against my clients in an efficient manner by scheduling depositions early in the discovery process. With notice well in advance, I believe that scheduling conflicts can be easily recognized and avoided. Enclosed is a Notice of Deposition directed to your client to take place on June 17, 2021 at 10:00 a.m. at Via Microsoft Teams. | will provide a court reporter at that time. If you would like to depose my client at the same time, kindly provide me with a Notice of Deposition. If this date is inconvenient, please contact my office to reschedule the deposition for another date, within fourteen (14) days. If I do not hear from you within fourteen (14) days of the date of this letter, I will assume that you are agreeable with the date of the deposition and we will proceed on that date. Thank you for your anticipated professional courtesies. Very truly yours, Kata 6 Earbette, Katie E. Barbetta, Esquire KEB/jah Enclosure QO re 9 cows HUBSHMAN, FLOOD, DORN, KOLB & SCHWEIKERT Not a Partnership, Not a Corporation SALARIED EMPLOYEES OF PROGRESSIVE CASUALTY INSURANCE COMPANY 5165 CAMPUS DRIVE, SUITE 200 PLYMOUTH MEETING, PA 19462 Katie E. Barbetta, Esquire Legal Assistant: Justin L. Garzone Direct #(610) 276-4984 Direct# (610) 276-4834 Facsimile #(866) 842-1482 justin_garzone@progressive.com KATIE_E_ BARBETTA@progressive.com May 3, 2021 Via Email Joel J. Kofsky, Esquire Law Offices Of Joel J. Kofsky, P.C. Two Penn Center Plaza 1500 JFK Boulevard, Suite 550 Philadelphia, PA 19102 RE: Salaam v. Knox Delaware County Court of Common Pleas No. CV-2021-001929 File No. 192631704-001 Dear Counsel: Please allow this correspondence to serve as a follow-up to my previous letter wherein I enclosed Interrogatories and a Request for Production of Documents addressed to your client. To date, I have not received your client’s responses. Please forward your client’s discovery responses within ten days from the date of this letter, or I will file a Motion to Compel. Thank you for your anticipated cooperation with regard to this matter. Very truly yours, Galli Haron? Jillian Hansberry, Administrative Assistant to Katie E. Barbetta, Esquire KEB/jah FILED 06-04-2021 10:07 AM OFFICE‘LAWARE OF JUDICIAL SUPPORT COUNTY,