Free Stipulation to EXTEND Time - District Court of Delaware - Delaware

Case 1 :07-cv-00117-IVIPT Document 32 Filed 11/19/2007 Page 1 of 3
IN THE DISTRICT COURT OF DELAWARE
IN AND FOR NEW CASTLE COUNTY
TAMMY HURD, :
Plaintiff,
v. C.A. No.: 07-l 17-MPT
DELAWARE STATE UNIVERSITY
and DANDESON PAN DA, individually :
and in his otiicial capacity, :
Defendants.
JOINT STIPULATION FOR EXTENSION OF TIME
Plaintiff Tammy Hurd and Defendants, Delaware State University and Dandeson Panda, by
and through their respective counsel, jointly stipulate to extend the time to complete discovery ,
and respectfully request that the Court adopt such amendment to this joint stipulation.
In support of this Motion, the parties state the following:
1. During the course of discovery it has come to the attention of the parties that they will
need to request a protective order to protect the distribution of confidential information in this
case. Said Order is being drafted and will be filed with the Court for it’s approval.
2. The need for a protective order has delayed taking the deposition of the Plaintiff and
the Defendants.
3. In accordance with the Court’s scheduling Order dated June 26, 2007, discovery in this
case is scheduled to conclude on December 4, 2007.
4. The parties agree that it will be diiiicult to conclude discovery by December 4, 2007
and therefore respectfully request that discovery in this matter be extended until April 30, 2008.
The parties agree that an extension of the discovery deadline should not impact or change any

Case 1:07-cv-00117-IVIPT Document 32 Filed 11/19/2007 Page 2 of 3
other dates previously set forth in the Court’s scheduling order.
WHEREFORE, Plaintiff Tammy Hurd and Defendants Delaware State University and
Dandeson Panda respectfully move the Court to amend the Scheduling Order to change the date
for completion of discovery from December 4, 2007 to April 30, 2008.
YOUNG, MALMBERG & HOWARD RICHARD R. WIER, JR., P.A.
/s/Ronald George Poliguin /s/Richard R. Wier, Jr.
Ronald George Poliquin (#4447) Richard R. Wier, Jr. (#716)
30 The Green Two Mill Road — Suite 200
Dover, DE 19901 Wilmington, DE 19806
(302)672-5600 (302)888-3222
Attorneyfar Plaintw Attarneyfar Dekndant - Dandeson Panda
WHITE & WILLIAMS, LLP
/s/ Marc Stephen Casarino
Marc Stephen Casarino (#3613)
824 North Market Street- Suite 902
PO Box 709
Wilmington, DE 19899-0709
(302)467-4520
Attorney for Dejendant — Delaware State University
Dated November 19, 2007

Case 1:07-cv-00117-IVIPT Document 32 Filed 11/19/2007 Page 3 of 3
IN THE DISTRICT COURT OF DELAWARE
IN AND FOR NEW CASTLE COUNTY
TAMMY HURD, :
Plaintiff,
v C.A. No.: 07-117-MPT
DELAWARE STATE UNIVERSITY
and DANDESON PANDA, individually :
and in his oiiicial capacity, :
Defendants.
ORDER
AND NOW, this day of , 2007, upon the joint stipulation of the parties
and for good cause shown, the time in which to extend discoveiy is amended as hereby set:
Discoveiy deadline April 30, 2008.

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