Free Stipulation - District Court of Delaware - Delaware

Case 1:06-cv—OOO27—SLR Document 21 Filed O9/25/2006 Page 1 of 2
IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF DELAWARE
PAULA PAGONAKIS, )
Plaintiff, 3
v. g NO. 1:06-CV-00027 (GMS)
EXPRESS LLC afk/a l
LIMITED BRANDS, INC., )
Defendant. g
STIPULATION TO CONTINUE DISCOVERY,
DISPOSITIVE MOTION AND MOTIONS IN LIMINE DEADLINES
Pursuant to Local Rule 16.5, Plaintiff Paula Pagonakis ("P1aintiff") and Defendant
Express, LLC ("Defendant”) (collectively referred to hereinafter as the "Parties") hereby agree
and stipulate to a short extension of the discovery, dispositive motion and motions in limine
deadlines and request approval from this Court. This request is being made before the expiration
of the discovery deadline. Pursuant to the Court’s April 20, 2006 Scheduling Order, the
discovery deadline is currently set for October 10, 2006; the dispositive motion deadline is set
for October 24, 2006; and motions in limine are due on January 29, 2007.
This request is being made because although the Parties have been diligently pursuing
discovery, they will be unable to complete all discovery before October 10, 2006. The Parties
have exchanged written discovery and are finalizing the exchange of doctunents. The Parties
have discussed scheduling depositions and are working together to find mutually available dates.
As the case schedule currently stands, the Parties are unable to schedule depositions before the
October 10, 2006 discovery deadline. Both lead counsel for Plaintiff and Defendant are located
out of state, requiring travel. Moreover, lead counsel for Defendant is scheduled to be in trial the
week of October 10, 2006. Accordingly, the Parties stipulate to the following proposed
extension of the case schedule:

Case 1:06-cv-00027-SLR Document 21 Filed O9/25/2006 Page 2 of 2
• Discovery cut off: December 1, 2006
• Dispositive motion deadline: December 15, 2006
• Motions in limine due: February 1, 2007
The Parties’ proposed extension will not affect the remaining case schedule, including the trial,
which is scheduled for April 23, 2007. Lead cotmsel for Plaintiff and Defendant certify that a
copy of this request has been provided to their clients. See attached Exhibit A.
Of counsel: By: /s/Sheldon IC Rennie (#3772)
David A. Campbell (#0066494) Francis G.X. Pileggi, Esquire (# 2624)
Admitted pro hac vice Sheldon K. Remiie, Esquire (#3772)
Lori L. Fauvie (#0076831) FOX ROTHSCHILD LLP
Admitted pro hac vice Citizens Bank Center
VORYS, SATER, SEYMOUR 919 North Market Street
AND PEASE LLP Suite 1300, 13th Floor
2100 One Cleveland Center Wilmington, DE 19801-2323
1375 East Ninth Street Telephone: 302-655-3667
Cleveland, Ohio 44114 Fax: 302-656-8920
Telephone: 2 16-479-6100 fpileggi(@,foxrod1schild.com
Fax: 216-479-6060 [email protected]
[email protected]
[email protected]
Of counsel s By: s/ Gg Aber (email consent via James
James C. Bailey (P.A. Bar #69086) C. Bailey) on 9-25-06
Jason H. Ehrenberg Gary Aber (I.D. # 754)
Bailey & Ehrenberg PLLC Aber, Goldlust, Baker & Over
1155 Connecticut Avenue NW 702 King Street
Suite 1100 P.O. Box 1675
Washington, D.C. Wilmington, DE 19899
Telephone; 202-787-3869 Telephone: 866 -826-4950
Fax: 202-318-7071 Fax: 302-472-4920
[email protected] [email protected]
J.
Dated: September , 2006
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