Free SO ORDERED - District Court of Delaware - Delaware


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Case 1 :06-cv-00077-JJF Document 34 Filed 12/11/2006 Page 1 of 2 T
IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF DELAWARE
BALDWIN GRAPHIC SYSTEMS, INC., )
Plaintiff, j
v. j C.A. N0. 06-77 (UF)
0 BBA NONWOVENS SIMPSONVILLE INC. j
and REEMAY INC., )
Defendants. j
STIPULATION AND PROPOSED ORDER TO EXTEND DATES SET FORTH
IN THE SEPTEMBER 26, 2006 AMENDED SCHEDULING ORDER
It is hereby stipulated by Plaintiff Baldwin Graphic Systems, Inc. ("Baldwin") and
Defendants BBA Nonwovens Simpsonville Inc. and Reemay Inc. (collectively "BBA"), subject
to the approval of the Court, that the deadline of December 29, 2006 set forth in paragraph 2(a)
the Amended Scheduling Order dated September 26, 2006 (D.I. 30) is extended by
approximately one month, as set forth in the attached Proposed Second Amended Scheduling
Order.
The reason for this stipulation is as follows. Settlement discussions have been
delayed because the senior management of Baldwin was involved in a major business acquisition
which has now been concluded. The parties are currently engaged in settlement discussions and
are continuing to explore a possible business resolution. As such, in the interest of judicial
economy and financial efficiency, the parties believe that the extension of time is appropriate.
As set forth in the attached certification, under Local Rule 16.5, counsel for
Baldwin and BBA have sent a copy of this request to their respective clients.

Case 1 :06-cv-00077-JJF Document 34 Filed 12/11/2006 Page 2 of 2
MORRIS, NICHOLS, ARSHT & TUNNELL LLP CONNOLLY BOVE LODGE & HUTZ, LLP
/s/ Leslie A. Polizoti /s/ Francis Di Giovanni
Jack B. Blumenfeld (#1014) Francis DiGiovanni (#3189)
Leslie A. Polizoti (#4299) Stephanie O’Byrne (#4446)
1201 N. Market Street The Nemours Building
P.O. Box 1347 1007 North Orange Street
Wilmington, DE 19899-1347 P.O. Box 2207
(302) 658-9200 Wilmington, DE 19899-2207
[email protected] (3 02) 888-6316
Attorneys for Plaintgf t`[email protected]
Baldwin Graphic Systems, Inc. Attorneys for Defendants, BBA Nonwovens
Simpsonville Inc. and Reemay Inc.
OF COUNSEL: OF COUNSEL:
James W. Gould Michael E. Zeliger
Keith J. McWha Christopher Centurelli
MORGAN & FINNEGAN, L.L.P. KIRKPATRICK & LOCKHART
3 World Financial Center NICHOLSON GRAHAM LLP
New York, NY 10281 State Street Financial Center
(212) 415-8700 One Lincoln Street
Boston, MA 02111-2950
(617) 261-3100
SO ORDERED this }‘9*day of O2 , 2006.
\ .
ximg SA
U @• State Di ct Judge
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