Free Motion for Pretrial - District Court of Delaware - Delaware

Case 1:06-cv-00068-JJF

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Filed 03/30/2007

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IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF DELAWARE ALVIA LACY, Plaintiff, v. NATIONAL RAILROAD PASSENGER CORPORATION, Defendant. * * * * * * * * * * * * * * * Case No. 1:06-CV-00068-UNA Judge: Unassigned

CONSENT MOTION TO POSTPONE PRETRIAL CONFERENCE Pro Se Plaintiff Alvia Lacy and Defendant National Railroad Passenger Corporation ("Amtrak"), hereby agree and stipulate as follows: 1. Pursuant to this Court's Scheduling Order dated August 15, 2006, a

Pretrial Conference was scheduled for March 8, 2007. The Pretrial Conference was cancelled as no proposed Pretrial Order was filed as required by Local Rule 16.5. 2. On December 7, 2006, Amtrak filed a Motion for Summary Judgment and

Opening Brief in Support. Plaintiff filed her Answering Brief in Opposition to Amtrak's Motion for Summary Judgment on December 27, 2006, to which Amtrak submitted a Reply Brief on January 8, 2007. 3. On March 28, 2007 Plaintiff filed a Motion Requesting that the Pretrial

Conference be rescheduled.

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4.

The parties conferred on Tuesday, March 20, 2007. At that time Plaintiff

told defense counsel that she had mailed her motion to reschedule the pretrial conference to the Court. After conferring, the parties agreed that it would be an unnecessary waste of judicial resources and the resources of the parties to hold a Pretrial Conference before the Court rules on Amtrak's Motion for Summary Judgment. 5. The parties now jointly respectfully request that the Court not reschedule

the Pretrial Conference unless one is necessary after a ruling on Amtrak's Motion for Summary Judgment. Respectfully submitted, /s/ Virginia A. Zrake Virginia A. Zrake, #4054 Law Office of Virginia A. Zrake, LLC 34382 Carpenters Way P.O. Box 247 Lewes, DE 19958 (302) 644-6770 [email protected]

/s/ Darrell R. VanDeusen Darrell R. VanDeusen, #08231 MD Clifton R. Gray, #27895 MD Kollman & Saucier, P.A. Sun Life Building, 8th Floor 20 South Charles Street Baltimore, MD 21201 (410) 727-4300 [email protected] Counsel for National Railroad Passenger Corporation CERTIFICATE OF SERVICE -2-

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I HEREBY CERTIFY that on this 30th day of March, 2007 a copy of the Consent Motion to Postpone Pretrial Conference was mailed, first class, postage prepaid to Ms. Alvia Lacy, 1306 Jervis Square, Belcamp, Maryland 21017, Plaintiff pro se.

/s/ Darrell R. VanDeusen Darrell R. VanDeusen

-3-

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IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF DELAWARE ALVIA LACY, Plaintiff, v. NATIONAL RAILROAD PASSENGER CORPORATION, Defendant. * * * * * * * * * * * * * * * Case No. 1:06-CV-00068-UNA Judge: Unassigned

ORDER The Court having received the Consent Motion to Postpone Pretrial Conference, it is this ______ day of ________________, 2007, hereby ORDERED that the Pretrial Conference will not be scheduled unless it is determined that one is necessary after a decision on Amtrak's Motion for Summary Judgment is rendered. ______________________________________ Joseph J. Farnan, Jr., United States District Court Judge