Free Motion for Extension of Time to File Response/Reply - District Court of Delaware - Delaware

Case 1:06-cv-00029-SLR

Document 41

Filed 12/14/2006

Page 1 of 2

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF DELAWARE

RIMMAX WHEELS, LLC, a Delaware limited liability company, Plaintiff, v. RC COMPONENTS, INC., a Kentucky corporation, Defendant. ______________________________________________________________________ MOTION FOR EXTENSION OF TIME TO FILE PLAINTIFF'S BRIEF IN OPPOSITION TO DEFENDANT'S MOTION FOR SUMMARY JUDGMENT And CERTIFICATION OF COMPLIANCE WITH LOCAL RULE 7.1.1 ______________________________________________________________________ COMES NOW the plaintiff, by its counsel, attorney Kester I.H. Crosse, and respectfully requests an extension of time to file plaintiff's brief in opposition to defendant's motion for summary judgment. The reason for this request is that attorney Crosse had an unexpected death in his family (his mother-in-law died this week), requiring he travel to Florida on December 14, 2006 for the funeral this weekend, and to attend to other pressing family business. Plaintiff's response to defendant's motion for summary judgment currently is due on December 18, 2006. Plaintiff requests an extension to December 29, 2006. Plaintiff understands it will lose its current trial date, which is set for March 2007. CIVIL ACTION NO. 06-029-SLR

1

Case 1:06-cv-00029-SLR

Document 41

Filed 12/14/2006

Page 2 of 2

CERTIFICATION OF COMPLIANCE WITH LOCAL RULE 7.1.1 Attorney Crosse hereby certifies he made a reasonable effort to reach agreement with opposing counsel on the matter set forth in this motion. Attorney Curtis Miller, representing defendant, opposes this motion. Dated this 14th day of December 2006.

s/ Kester I.H. Crosse WILLIAMS & CROSSE Kester I.H. Crosse, Esq. [Bar I.D. 638] 1214 King Street Suite 300 Wilmington, DE 19801 Telephone: (302) 652-3141 E-Mail: [email protected]

CERTIFICATE OF SERVICE I hereby certify that on December 14, 2006, I electronically filed with the Clerk of Court using CM/ECF which will send notification of such filing(s) to the following: Attorney Curtis Miller E-mail: [email protected]

s/ Kester I.H. Crosse

2