Free Motion for Extension of Time to Complete Discovery - District Court of Delaware - Delaware

Case 1 :07-mc—00068-JJF Document 4 Filed 05/21/2007 Page 1 of 2
IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF DELAWARE
Application of NURIT MILLER for §
an Order Requiring STAR NIGHT §
USA INC. to Produce Information § No. 1:07-mc-00068-JJF
and Documents For Use in an Action §
Pending in the Courts of the State §
of Israel §
MOTION FOR EXTENSION OF DEADLINE
1. On March 28, 2007, Applicant Nurit Miller tiled an application for a discovery
order pursuant to 28 U.S.C. §1782. On May 1, 2007, the Court ordered Respondent to respond
to Applicant’s discovery requests within twenty (20) days from the date of the Order.
2. Respondent has indicated its readiness to respond to Applicant’s requests.
Respondent has requested additional time, however, for collecting and supplying the requested
information. Applicant has no objection to a limited extension of the time for response.
PRAYER FOR RELIEF
3. Applicant Nurit Miller prays for an order of this Court extending the time for
response set in the Comt’s original Order, to permit response on or before June 18, 2007.
Respectfully submitted,
FOR APPLICANT NURIT MILLER
Dated: May 18, 2007
Leonard Schoen, Esq.
150 Draper Lane, Suite 1BN
Dobbs Ferry, NY 10522
Telephone: (914) 414-7615
Facsimile: (914) 674-0747
New York State Bar Number: 2307999

Case 1:07-mc-00068-JJF Document 4 Filed 05/21/2007 Page 2 of 2
IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF DELAWARE
Application of NURIT MILLER for §
an Order Requiring STAR NIGHT §
USA INC. to Produce Information § No. 1:07-mc-00068-JJF
and Documents For Use in an Action §
Pending in the Courts of the State §
of Israel §
ORDER
WHEREAS, the Court ordered the production of information pursuant to 28 U.S.C. §1782 in an
Order dated May 1, 2007; and
WHEREAS, Applicant has requested that the time for Respondent’s response be extended.
IT IS HEREBY ORDERED that Star Night USA respond to Applicant’s Interrogatories and
Requests for Production of Documents, on or before June 18, 2007. A copy of this Order shall
be sufficient for the purpose of service.
This day of , 2007
UNITED STATES DISTRICT JUDGE

Case 1 :07-mc-00068-JJF Document 4-2 Filed 05/21 /2007 Page 1 of 1
Leonard Schoen, Esq.
May 18, 2007
United States District Court for the District of Delaware
Attention: Deborah Krett Case Manager for Judge Joseph J. Faman, Jr.
J. Caleb Boggs Federal Building
844 N. King Street
Room 4124
Lockbox 27
Wilmington, DE 19801
Subject: ln re Application ofNurit Miller
Civil Case 1:07-mc-00068-JJF
On March 28, 2007, Applicant Nurit Miller filed an application for a discovery order
pursuant to 28 U.S.C. §1782. On May 1, 2007, the Court ordered Respondent to
respond to App1icant’s discovery requests within twenty (20) days from the date of
the Order.
The parties have had a series of discussions and Respondent has indicated its
readiness to respond to Applicant’s requests. Respondent has requested additional
time, however, for collecting and supplying the requested information. Applicant has
no objection to a limited extension of the time for response.
In light of the above, Applicant seeks an extension of the time for response set in the
Couit’s original Order, to permit response on or before June 18, 2007.
A fom1al Motion for Extension of Deadline is enclosed.
Sincerely,
Leonard Schoen, Esq.
For Applicant Nurit Miller
150 Draper Lane, Suite 1BN, Dobbs Ferry, NY 10522
Telephone: 914-414-7615 Fax: 91+674-0747
Email: [email protected]