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

Case 1:06-cv-00065-SLR

Document 15

Filed 01/30/2007

Page 1 of 3

UNITED STATES DISTRICT COURT FOR THE DISTRICT OF DELAWARE

GARY BAER and JODI BAER Plaintiffs, v. THE UNITED STATES OF AMERICA, Defendant.

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C.A. No. 06-0065-SLR

STIPULATION AND ORDER REGARDING DISCOVERY CUT OFF It is hereby STIPULATED and AGREED by and between Plaintiffs and Defendant, subject to the approval of the Court, that: The discovery deadline in this case is extended until February 16, 2007. In support of this Stipulation, the parties state as follows: Plaintiffs have served interrogatories and taken depositions. Defendant has not yet conducted discovery due to its difficulty in finding an appropriate expert in this matter, and in obtaining a report from that expert. A report from Defendants' expert is expected the week of January 29, 2007. Defendant expects to then take the deposition of Plaintiff Gary Baer prior to the February 16, 2007 discovery cut-off. Dated: January 30, 2007. COLM F. CONNOLY United States Attorney /s/ Vincent A. Bifferato, Jr. Vincent A. Bifferato, Jr. (#2465) Bifferato, Gentilotti, Biden, & Balick, P.A. 200 Biddle Avenue, Suite 203 Newark, DE 19702 /s/ Seth M. Beausang Seth M. Beausang (#4071) Assistant U.S. Attorney 1007 N. Orange Street, Suite 700 Wilmington, DE 19801

Case 1:06-cv-00065-SLR

Document 15

Filed 01/30/2007

Page 2 of 3

UNITED STATES DISTRICT COURT FOR THE DISTRICT OF DELAWARE

GARY BAER and JODI BAER Plaintiffs, v. THE UNITED STATES OF AMERICA, Defendant.

: : : : : : : :

C.A. No. 06-0065-SLR

ORDER AND NOW, this __________ day of _________________, 2007, upon consideration or the parties' joint Stipulation Regarding Discovery Cut Off, it is ORDERED that all discovery in this case shall be initiated so that it will be completed on or before February 16, 2007.

___________________________________ UNITED STATES DISTRICT JUDGE

Case 1:06-cv-00065-SLR

Document 15

Filed 01/30/2007

Page 3 of 3

CERTIFICATE OF SERVICE I, Seth M. Beausang, hereby attest under penalty of perjury that on this 30th day of January, 2007, I caused a copy of the Parties' Stipulation and Order Regarding Discovery Cut Off to be served on the following counsel for Plaintiffs by ECF: Vincent A. Bifferato, Jr. 200 Biddle Avenue, Suite 203 Springside Plaza Newark, Delaware 19702 (302) 429-1900 (302) 832-7540 (fax)