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

Case 1:06-cv-00274-GMS

Document 19

Filed 04/23/2007

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IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF DELAWARE CHRISTINA LIEF F/B/O TASHA LIEF, Plaintiff, v. CAPE HENLOPEN SCHOOL DISTRICT and the DELAWARE DEPARTMENT OF EDUCATION, Defendants * * * * * Civil Action No. 06-274-GMS

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STIPULATED MOTION FOR EXTENSION OF TIME FOR DISCOVERY AND FOR FILING DISPOSITIVE MOTIONS

The parties, by and through their attorneys, hereby submit this request for extension of time for discovery and for the filing of dispositive motions, and for reasons state: 1. That a Scheduling Order was issued by this Court on January 26, 2007, setting

May 25, 2007, as the date for completion of discovery in this matter, and that case dispositive motions would be due on June 8, 2007. 2. That at that time, the Plaintiff was represented by counsel who has since

withdrawn. A Motion to Substitute Attorney was filed on April 11, 2007 and granted on April 12, 2007. 3. That given that the Plaintiff has retained new counsel who required additional

time to evaluate the case, all parties agree that it would be appropriate and in the interest of justice to extend the deadlines for discovery and for filing case dispositive motions.

Case 1:06-cv-00274-GMS

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Filed 04/23/2007

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WHEREFORE, the parties respectfully request that the discovery deadline in this case be extended until June 29, 2007, and that the deadline for filing case dispositive motions be extended until July 20, 2007.

Respectfully submitted,

Dated: April 23, 2007

/s/ Bruce L. Hudson Bruce L. Hudson, Esq. (No. 1003) 800 N. King Street, Suite 302 Wilmington, DE 19801 Telephone: 302-656-9850 Facsimile: 302-656-9836 Attorney for Plaintiff

/s/ Wayne D. Steedman Wayne D. Steedman, Esq. (No. 9474) Callegary and Steedman, P.A. 301 North Charles Street, Suite 600 Baltimore, MD 21201 Telephone: 410-576-7606 Facsimile: 410-576-0454 Attorney for Plaintiff

/s/ Michael P. Stafford Michael P. Stafford, Esq. (No. 4461) Young Conaway Stargatt & Taylor, LLP The Brandywine Building 1000 West Street, 17th Floor P.O. Box 391 Wilmington, DE 19899 Telephone: 302-571-6553 Facsimile: 302-576-3461 Attorney for Defendant Cape Henlopen School District

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Case 1:06-cv-00274-GMS

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Filed 04/23/2007

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/s/ Craig R. Fitzgerald Craig R. Fitzgerald, Esq. (No. 3730) Deputy Attorney General State of Delaware Department of Justice 820 North French Street ­ 6th Floor Wilmington, DE 19801 Telephone: 302-577-8400 Attorney for Defendant Delaware Department of Education

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