Free Motion to Stay - District Court of Delaware - Delaware

Case 1 :07-cv-00174-GIVIS Document 22 Filed 08/O2/2007 Page 1 of 2
IN THE UNITED STATES DISTRICT COURT
FOR Tl-IE DISTRICT OF DELAWARE
ALEXANDER FABRICS, LLLP, ·
riarnarr Z
v. C.A. No. l:07—cv—0Ol74 GMS
ROKA APPAREL PRODUCTS, LLC
Defendant.
DEFENDANT ROKA APPAREL
PRODUCTS, LLC’S MOTION TO STAY
Defendant Roka Apparel Products, LLC ("Defendant"), by and through its
undersigned counsel, hereby moves for an Order staying this litigation pending the final
disposition of a related action tiled in Florida in which the parties can obtain complete
relief on their claims, all of which arise under state law. The grounds for the Motion are
fully set forth in Defendant Rcka Apparel Products, LLC’s Memorandum of Law in
Support of Motion to Stay, which is incorporated herein by reference.
WHEREFORE, Defendant respectfully requests that the Court stay this case in
favor ofthe action pending in Florida and grant such further relief as the Court deems just
and proper.
Respectfully submitted,
',
By: A 4;
raim C. l1ips, (#1l0)
PHILLWS, GOLDMAN & SPENCE, PA.
1200 N. Broom Street
Wilmington, Delaware 19806
Tel. No. (302) 655-4200
... and F.

Case 1 :07-cv-00174-GIVIS Document 22 Filed 08/O2/2007 Page 2 of 2
Barbara Slott Pegg
Attorney at Law
316 Sea Moss Lane
Ponte Vedra Beach, Florida 32082
Tel. No. (904) 2858100
Attorneys for Defendant,
Rolia Apparel Products, LLC
Dated: August 2, 2007

Case 1 :O7—cv—OO174-GI\/IS Document 22-2 Filed 08/O2/2007 Page 1 of 1
IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF DELAWARE
ALEXANDER FABRICS, LLLP,
Ptamtttt, E
v. C.A. No. l:07—cv—00l74 GMS
ROKA APFAREL PRODUCTS, LLC
Defendant.
ORDER
AND NOW, this day of , 2007, upon consideration of
Defendant Roka Apparel Froducts, LLC’s Motion to Stay (the "}.\/Iotion") and any response
thereto;
IT IS HEREBY ORDERED that the Motion is GRANTED.
IT IS HEREBY FURTHER ORDERED that this action is stayed pending the final
disposition of the lawsuit currently pending between the parties in the Circuit Court, Fourth
Judicial Circuit in and for Duval County, Florida, Case No.16—2007—CA-0001 5 1.
The Honorable Gregory M. Sieet

Case 1 :O7—cv—OO174-GI\/IS Document 22-3 Filed 08/O2/2007 Page 1 of 1
Rule 7.1.1 Certification
Counsel for Defendant hereby certify that they made a reasonable effort to resolve the
issues set forth in Defendant Roka Apparel Products, LLC’s Motion to Stay with Plaintiff s
counsel; however, Plaintiffs counsel opposes the relief sought therein.
/s/Ioim C. Phillips, Jr.
John C. Phillips, lr. (#1 10)