Free Motion to Amend/Correct - District Court of Delaware - Delaware

Case 1:06-cv-00017-GMS

Document 15

Filed 06/18/2007

Page 1 of 2

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF DELAWARE JAY RINGGOLD, Plaintiff, v. OFFICER THOMAS CURLEY and OFFICER NELIDA VEGA Defendants. : : : : : : : : : :

C.A. No. 06-17 GMS TRIAL BY JURY DEMANDED

DEFENDANTS' MOTION TO AMEND THE RULE 16 SCHEDULING ORDER TO EXTEND THE DISCOVERY AND CASE DISPOSITIVE MOTIONS DEADLINES Defendants, by and through counsel, hereby move this Honorable Court to Amend the Rule 16 Scheduling Order to extend the discovery and case dispositive motions deadlines. In support of their Motion, Defendants offer the following: 1. Currently, the discovery deadline is June 20, 2007. The deadline for case dispositive

motions is August 20, 2007. No trial date has been set in this matter. 2. Due to several other pending matters, counsel for Defendants did not realize until

recently that discovery in this matter closes June 20, 2007. 3. Therefore, Defendants respectfully request that the discovery and case dispositive

deadlines be extended to September 21, 2007 and October 15, 2007, respectively. 4. Defendants' do not believe that an extension would prejudice Plaintiff as he has not

engaged in formal discovery and an extension would afford him another opportunity to do so. 5. Counsel is unable to contact Plaintiff concerning his position with regard to this

Motion because Plaintiff is currently incarcerated.

Case 1:06-cv-00017-GMS

Document 15

Filed 06/18/2007

Page 2 of 2

WHEREFORE, Defendants respectfully request that this Honorable Court amend the Rule 16 Scheduling Order to extend the above referenced deadlines.

/s/ Rosamaria Tassone Rosamaria Tassone, Esq. (I.D. #3546) First Assistant City Solicitor Louis J. Redding City/County Bldg. 800 N. French St., 9th Flr. Wilmington, DE 19801 Attorney for Defendants

Dated: June 18, 2007