In Wright v. Moore, (Del. Supr., June 17, 2008), read opinion here, the Delaware Supreme Court addressed yesterday the standard that applies to requests for modifications of pre-trial orders which control such things as discovery deadlines and the like. The specific issue in this interlocutory appeal was whether the trial judge abused her discretion for refusing to allow for new discovery after the Supreme Court remanded and reversed the case last year for a new trial. The court discussed the "manifest injustice" test under Rule 16(e) and found that it did apply here. Delaware’s High Court also took the unusual step of ordering that the case be assigned to a different trial judge.