Free Motion for Extension of Time - District Court of Delaware - Delaware

Case 1:05-cv-00010-JJF Document 78 Filed O2/O2/2006 Paget of 3
IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF DELAWARE
BRIAN MILLER, et al. ,
Plaintiffs,
Civil Action No. 05-010-JJF
v.
COMPUTER SCIENCES CORPORATION,
Defendant.
JOINT MOTION TO EXTEND THE SCHEDULING ORDER
The parties, by their undersigned coimsel, hereby move this Honorable Court for an
extension of the case Scheduling Order. The parties have propounded discovery requests and
have served discovery responses, but still need additional time to complete depositions.
Currently, the parties have completed four depositions and have seven more depositions
scheduled for the month of February. In addition to these depositions, Plaintiffs seek to depose a
Computer Sciences Corporation ("CSC") employee, Mary Jo Morris, as well as several other
CSC employees. Ms. Morris will be leaving the United States shortly for India, where she will
be working until approximately the middle of March 2006. Given Ms. Morris’ schedule, and
that of counsel for the parties, the deposition of Ms. Morris cannot be held prior to the current
dispositive motion deadline of March 17, 2006. The parties also anticipate possible scheduling
difficulties in arranging other depositions requested by Plaintiffs.
An extension of the scheduling order will not impose any inconvenience on the Court as
there are no pretrial or trial dates scheduled in this action other than the Pretrial Conference

Case 1:05-cv-00010-JJF Document 78 Filed O2/O2/2006 Page 2 of 3
scheduled for May 4, 2006. The parties request that the Scheduling Order be amended to reflect
the following changes:
7. Case Dispositive Motions. Any case dispositive motions, pursuant to the
Federal Rules of Civil Procedure, shall be served and filed with an opening brief on or before
April 28, 2006.
9. Pretrial Conference and Trial. The Court will schedule a Pretrial
Conference, if necessary, promptly after issuing any decision upon any case dispositive motion.
The scheduling of the trial date will be deferred until the Pretrial Conference.
Respectfully submitted,
/s/ Timothy J. Wilson /s/ Sarah E. DiLuzio
Timothy J. Wilson, Esq. (#4323) Sarah E. DiLuzio (#4085)
MARGOLIS EDELSTEIN POTTER ANDERSON & CORROON LLP
1509 Gilpin Avenue 1313 North Market Street, 6th Floor
Wilmington, Delaware 19806 P. O. Box 951
(302) 777-4680 Wilmington, Delaware 19801
(301) 777-4682 (fax) (302) 984-6000 (general)
(302) 984-6279 (direct)
Attorney for Plaintiffs (302) 658-1192 (fax)
[email protected]
Larry R. Seegull (admitted pro hac vice)
Linda M. Boyd (admitted pro hac vice)
DLA PIPER RUDNICK GRAY CARY U.S. LLP
6225 Smith Avenue
Baltimore, Maryland 21209
(410) 580-3000 (general)
(410) 580-4253 (direct)
(410) 580-3253 (fax)
[email protected]
Attomeys for Defendant,
Computer Sciences Corporation
February 2, 2006
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Case 1:05-cv-00010-JJF Document 78 Filed O2/O2/2006 Page 3 of 3
IT IS SO ORDERED this day of , 2006, that the
foregoing changes to the Scheduling Order are adopted.
The Honorable Joseph J. Farnan, Jr.
United States District Judge
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