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

Case 1:07-cv-00013-GMS

Document 5

Filed 01/26/2007

Page 1 of 2

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF DELAWARE

DIANE RECZEK, Plaintiff, v. TILTON TERRACE OF DELAWARE, L.L.C. d/b/a TILTON TERRACE; and, JHA WILMINGTON, INC., Defendants.

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C.A. No. 07-00013-GMS

STIPULATION FOR EXTENSION OF TIME WHEREAS, Defendant JHA Wilmington, Inc. was unable to retain counsel to represent it in connection with this action until January 23, 2007; and WHEREAS, counsel for JHA Wilmington, Inc. is unable to fully investigate the facts of the case to prepare an adequate response to the Complaint prior to the existing deadline of January 30, 2007; and WHEREAS, counsel for both parties believe that a two-week extension will not substantially impact the parties' rights or delay the processing of the litigation; NOW, THEREFORE, it is hereby stipulated, subject to the approval of the Court, that the time in which Defendant JHA Wilmington, Inc. may respond to the Complaint is hereby extended from January 30, 2007 to February 13, 2007. A proposed form of Order is attached hereto.

Case 1:07-cv-00013-GMS

Document 5

Filed 01/26/2007

Page 2 of 2

Case 1:07-cv-00013-GMS

Document 5-2

Filed 01/26/2007

Page 1 of 1

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF DELAWARE

DIANE RECZEK, Plaintiff, v. TILTON TERRACE OF DELAWARE, L.L.C. d/b/a TILTON TERRACE; and, JHA WILMINGTON, INC., Defendants.

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C.A. No. 07-00013-GMS

Re: Docket No.

ORDER GRANTING EXTENSION OF TIME The Court having considered the Stipulation for Extension of Time (the "Stipulation"), entered into by Plaintiff and Defendant JHA Wilmington, Inc. and the Court having determined that good and adequate cause exists for approval of the Stipulation; IT IS HEREBY ORDERED that the Stipulation is approved; and IT IS FURTHER ORDERED that the time for Defendant JHA Wilmington, Inc. to respond to the Complaint is extended through and including February 13, 2007.

Dated:

, 2007 Judge Gregory M. Sleet