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

Case 1 :07-cv-00159-GIVIS Document 10 Filed 04/13/2007 Page 1 of 2
IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF DELAWARE
BANK OF AMERICA, N.A. ) I
)
Plaintiff, ) Civil Action No. 07-159
)
v. )
)
SIP ASSETS, LLC AND )
EVERY PENNY COUNTS, INC )
)
Defendants. ) -
DEFENDANT’S MOTION FOR EXTENSION OF TIME
SIP ASSETS, LLC as Defendant named in the Complaint respectfully requests that the Court:
grant SIP ASSETS, LLC an additional 30 days to file a responsive pleading, and as grounds
therefor, states that Defendant has been unable to obtain the services of counsel in the State of
Delaware as of this date. l
Wherefore, defendant prays for an order granting it additional time to file a responsive pleading
up to May 9, 2007, and for whatever other order is just and proper under the circumstances.
Respectfully submitted,
_//’Edward Grau, Director i
S.I.P Assets, LLC
1466 Broadway, Suite 1200 `
New York, NY, 10036
Phone: (646) 662-2366 ,
Dated: April 6, 2007. i

Case 1 :07-cv—00159-GIVIS Document 10 Filed 04/13/2007 Page 2 of 2
I, Edward Grau, hereby certify that on April 6, 2007: Ai
I caused two copies of DEFENDANT’S MOTION FOR EXTENSION OF TIME to be served
upon the following persons by Federal Express delivery:
Clerk’s Office
United States District Court for the District of Delaware .
844 N. King Street Room 4209
Wilmington, DE 19801
Phone: 302-573-6170
I caused two copies of DEFENDANT’S MOTION FOR EXTENSION OF TIME to be served
upon the following persons by Federal Express delivery:
Attn: Richard L. Horwitz, Esq. and Kenneth L. Dorsney, Esq.
Potter Anderson & Corroon LLP
Hercules Plaza
1313 North Market Street
Wilmington, DE 19899
Phone: 302-984-6000 1
/ Edward Grau, Director l _
l S.I.P Assets, LLC
1466 Broadway, Suite 1200
New York, NY, 10036 y
Phone: (646) 662-2366 .

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