Free Motion for Extension of Time to File Response/Reply - District Court of Delaware - Delaware

Case 1:07-mc—OO125-JJF Document 11 Filed O3/25/2008 Page 1 of 4
UNITED STATES DISTRICT COURT
FOR DISTRICT OF DELAWARE
In re: Chapter I1
KAISER GROUP INTERNATIONAL, Case N0. 00-2263 (MFW)
INC., et al., Adv. No. 01-928( (MW)
Debtors. (Jointly Administered)
KAISER INTERNATIONAL, INC., et :
al., 2
Appellant,
v. Case No. 07-124 (JJF)
ARCELORMITTAL STEEL OSTRAVA
a.s., formerly known as NOVA HUT a.s. :
and INTERNATIONAL FINANCE :
CORPORATION, :
: Related to Docket No. 6
A ellees. :
KAISER INTERNATIONAL, INC., et
al.,
Plaintiffs,
v. Case No. No. 07-125 (JJF)
ARCELORMITTAL STEEL OSTRAVA
a.s., formerly known as NOVA HUT a.s.
and INTERNATIONAL FINANCE
CORPORATION,
Related to Docket No. 8
Defendants.
STIPULATION AND ORDER REGARDING EXTENSION OF TIME
TO FILE REPLY IN SUPPORT OF DEBTORS’ MOTION FOR LEAVE TO
SUPPLEMENT THE RECORD OR, ALTERNATIVELY, TO REMAND
THE CASE TO THE BANKRUPTCY COURT FOR RECONSIDERATION BASED
ON NEWLY DISCOVERY EVIDENCE PURSUANT TO RULE 60(b)|2[
This Stipulation (the "Stipulation") is entered into by appellants Kaiser Intemational, Inc.,
et al. ("Kaiser"), and appellees Arcelorlvlittal Steel Ostrava, a.s., formerly known as Nova Hut
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Case 1:07-mc—OO125-JJF Document 11 Filed O3/25/2008 Page 2 of 4
a.s. ("ArcelorMittal") and Intemational Finance Corporation ("IFC") in the above-captioned
cases, by and through their counsel, and is based upon the following facts:
RECITALS
1. On or about March 6, 2008, Kaiser tiled the Debtors’ Motion for Leave to
Supplement the Record or, Alternatively, to Remand the Case to the Bankruptcy Court for
Reconsideration Based on Newly Discovery Evidence Pursuant to Rule 60(b)(2) (the "Motion")
[Docket Nos. 6 and 8] in the above captioned cases.
2. On or about March 17, 2008, Arce1orMittal tiled its Cross-Motion for Damages
and Costs Pursuant to Federal Rule of Bankruptcy Procedure 8020 [Docket Nos. 8 and 9] and its
Memorandum of Law in Opposition to the Motion and in Support of its Cross—Motion [Docket
Nos. 9 and 10].
3. On or about March 17, 2008, IFC tiled its Opposition to the Motion [Docket No.
7].
4. Pursuant to Local Rule 7.l.2(b), Kaiser’s reply in support of the Motion is due
March 25, 2008.
5. The parties agree and stipulate to extend the response date by which Kaiser must
tile its reply in support of the Motion until April 1, 2008.
6. This Stipulation is without prejudice to request further extensions.
IN CONSIDERATION OF THE FOREGOING, it is hereby stipulated by and between
the parties, by and through their respective counsel, as follows:
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Case 1:07-mc—0O125-JJF Document 11 Filed O3/25/2008 Page 3 of 4
STIPULATION
A. The date by which Kaiser may file its reply in support of the Motion shall be
extended until and including April 1, 2008.
B. This Stipulation may be executed in counterparts, which shall be considered
together as a single document. Furthermore, this Stipulation may be executed by facsimile copy,
and facsimile signatures will be treated as original signatures.
C. This Stipulaiion is without prejudice to any request(s) further extensions.
IT IS SO STIPULATED.
SAUL EWING LLP GREENBERG TRAURIG, LLP
By I ° By
Mark Minuti (No. 2659) Victoria Counihan (No. 488)
Jeremy W. Ryan (No. 4057) Dennis Meloro (No. 4435)
222 Delaware Ave., Suite 1200 The Nemours Building
P.O. Box 1266 1007 North Orange Street, Suite 1200
Wilmington, DE 19899 Wilmington, DE 19801
(302) 421-6840 (302) 661-7000
Attomeys for Appellants Kaiser -and—
Intemational, Inc., et al.
Adam D. Cole
885 Third Avenue
New York, NY 10022
(212) 848-1000
Attorney for Appellee Arcelo1·Mittal Steel Ostrava,
a.s. (formerly Nova Hut, a.s.)
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Case 1:07-mc—OO125-JJF Document 11 Filed O3/25/2008 Page 4 of 4
RICHARDS, LAYTON & FINGER, P.A.
By 2-
Robert J. St , Jr. (No. )
Lee E. Kaufman (No. 4877)
One Rodney Square
P.O. Box 551
Wihnington, DE 19899
(302) 651-7700
..aJ`1d-
Warren E. Zirkle
McGUIRE WOODS LLP
1750 Tysons Blvd., Suite 1800
McLean, VA 22012
(703) 712-5000
Attomeys for Appellee International
Finance Corporation
Dated: March 'QL5, 2008
SO ORDERED this __ day of , 2008
Joseph J. Farnan, Jr.
United States District Court Judge
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