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

Case 1:07-cv-00176-SLR

Document 27

Filed 05/07/2007

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IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT COURT OF DELAWARE

: : : Plaintiffs, : : V. : : STATE FARM MUTUAL AUTOMOBILE : INSURANCE COMPANY, : : Defendant : ORDER

KENNETH REYNOLDS and JOAN CHIEN, husband and wife,

C.A. No.:

07-cv-176

AND NOW, this _______ day of _______, 2007 upon consideration of Plaintiff's Motion for An Extension of Time to Enter Local Counsel, and any response thereto, it is hereby ORDERED and DECREED that Plaintiff's motion is GRANTED. Local Counsel for Plaitniff's shall enter their appearance by ____________________.

___________________________ J.

Case 1:07-cv-00176-SLR

Document 27

Filed 05/07/2007

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IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT COURT OF DELAWARE

: : : Plaintiffs, : : V. : : STATE FARM MUTUAL AUTOMOBILE : INSURANCE COMPANY, : : Defendant :

KENNETH REYNOLDS and JOAN CHIEN, husband and wife,

C.A. No.:

07-cv-176

MOTION FOR AN EXTENSION OF TIME TO ENTER LOCAL COUNSEL

Plaintiffs Kenneth Reynolds and Joan Chien, by and through out of state counsel, hereby move this Honorable Court for an Extension of Time to Enter Local Counsel and in support thereof aver: 1. 2. This case was originally brought in the Eastern District of Pennsylvania. By Court Order of the Eastern District, the case was transferred to this Judicial

District. 3. This Honorable Court entered an Order requiring all Parties to enter the

appearance of local counsel by May 7, 2007. 4. Plaintiffs entered into discussions and/or negotiations with a local counsel and

met with that attorney (who is also licensed in Pennsylvania) on more than one occasion. 5. Plaintiffs have just learned that the local counsel whom was to represent them has

a potential conflict of interest and is unable to enter his appearance at this time.

Case 1:07-cv-00176-SLR

Document 27

Filed 05/07/2007

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WHEREFORE, Plaintiffs request an additional reasonable time to enter the appearance of local counsel. Respectfully Submitted /s/Shelly Farber ___________ SHELLY FARBER, ESQUIRE Out of State Attorney for Plaintiffs 2619 West Chester Pike Broomall, Pa 19008 (610) 356-3900

Case 1:07-cv-00176-SLR

Document 27

Filed 05/07/2007

Page 4 of 4

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT COURT OF DELAWARE

KENNETH REYNOLDS and JOAN CHIEN, husband and wife,

: : : Plaintiffs, : : V. : : STATE FARM MUTUAL AUTOMOBILE : INSURANCE COMPANY, : : Defendant :

C.A. No.:

07-cv-176

CERTIFICATE OF SERVICE I Shelly Farber, Esquire aver that on May 7, 2007 I caused a true and correct copy of the attached Motion via mail upon: Sherry Ruggiero Fallon, Esquire 750 South Madison Street #400 P.O. Box 2092 Wilmington, DE 19899-2092 (Attorney for Defendant)

Respectfully Submitted /s/Shelly Farber ___________ SHELLY FARBER, ESQUIRE Out of State Attorney for Plaintiffs 2619 West Chester Pike Broomall, Pa 19008 (610) 356-3900