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


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Case 1 :06-cv-00013-SLR Document 23 Filed 10/27/2006 Page 1 of 4
IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF DELAWARE
SENTILLION, INC.,
Plaintiff and Counterclaim Defendant, Civil Action No.: 06-013 (SLR)
v.
CAREFX CORP., JURY TRIAL DEMANDED
Defendant and Counterclaim Plaintiff.
UNOPPOSED MOTION TO AMEND SCHEDULING ORDER
Plaintiff and Counterclaim Defendant Sentiilion, inc. ("Sentillion") respectfully requests that
the Court modify the Rule I6 Scheduling Order entered by the Couit on May 30, 2006 (the
"Scheduling Order") (DJ. 16) in two respects: (I) to move the deadline for the completion of
document production from November l, 2006 to November 22, 2006, and (2) to move the in—person
discovery status conference currently scheduled November 2, 2006 to a time after November 22,
2006 that is convenient to the parties and Court. Defendant and Counterclairn Plaintiff Caretir Corp.
("Carefx") does not oppose the relief sought herein. Sentillion makes this motion for the following
reasons:
i. The Scheduling Order currently provides that the parties will complete document
production on or before November I, 2006. See DI. l6 at 'll 2(b)( l ). It similarly provides that an in-
person discovery status conference shall take place on November 2, 2006 at 4:30 p.m. See id at ll
2(0(1)»
2. The parties are currently in the process of completing document production.
Sentillion has learned that it will need additional time beyond November I, 2006 in order to
complete its document production. Sentiilion informed Carefx of Sentillion’s need for additional
RLF1-3074782-1

Case 1:06-cv-00013-SLR Document 23 Filed 10/27/2006 Page 2 of 4
time, and Carefx agreed not to oppose Sentillion's request for three additional weeks to complete
document production. The parties have agreed to produce documents on a rolling basis until
production is complete, including a substantial volume of documents on November 1. Sentillion
therefore respectfully requests that paragraph 2(b)( 1) ofthe Scheduling Order be modified to extend
the deadline for the completion of document production to November 22, 2006. The Court's granting
three additional weeks to complete document production will not jeopardize the parties' ability to
complete discovery in accordance with the other deadlines of the Scheduling Order, and will not
affect any other deadlines in the Scheduling Order.
4. Should the Court grant this motion and extend the deadline for the completion of
document production to November 22, 2006, Sentiliion further respectfully requests that the in-
person discovery status conference currently scheduled for November 2, 2006 be rescheduled for a
time convenient to the parties and the Court after November 22, 2006. To the extent the discovery
status conference is intended to address any issues relating to the parties' document production,
Sentillion submits that those issues will be best addressed following the completion of document
production. Carefx does not oppose this request.
WHEREFORE, for the foregoing reasons, Sentillion respectfully requests, and Carefx does
not oppose, that the Court enter its proposed form of Order attached heretor
X/E D,/4. tn reamaza
OF COUNSEL° Jeffrey L'. Moyer (ID NO. 3309)
lfcom
Maeiiew u. Lawrie, seo No, 563,414 ‘“°y€l@' ,
Aaron w. Meme, eso N0. 63 sms K Tylar O GOWN (ID N2 45 M)
. . oconnell@rlfYcom
Lowrie, Lando & Anastasi, LLP . .
. Richards, Layton & Finger, PA.
Riverfront Office Park
. _ One Rodney Square
One Main Street- llth Floor
. P.O. Box 551
Cambridge, Massachusetts 02142 W.} . D 1 19899
(617) 395-7000 1 mington, e aware
(302) 65 i-7700
Dated: October 27: 2006 Attorneys for Sentiilion, Inc.
-2-
RLF1-3o74782-1

Case 1:06-cv-00013-SLR Document 23 Filed 10/27/2006 Page 3 of 4
CERTIFICATION PURSUANT TO
DISTRICT OF DELAWARE LOCAL RULE 7 .1 .1
Pursuant to Local Rule 7.1.1, counsel for Plaintiff and Countercleim Defendant
Sentillion, Inc. ("Sentillior1") has consulted with counsel for Defendant and Counterelaim
Plaintiff Carefx Corp. ("Carefx") and determined that Carefx consents to the relief sought in the
attached motion.
j. ,);,4p #14:.4%,9 {
K.Tyle O'Connell(#451 )
Rm-suvws-1

Case 1:06-cv-00013-SLR Document 23 Filed 10/27/2006 Page 4 of 4
IN THE UNITED STATES DISTRICT COURT
DISTRICT OF DELAWARE
CERTIFICATE OF SERVICE
I hereby certify that on October 27, 2006, l electronically filed the foregoing document
with the Clerk of Court using CM/ECP which will send notitication of such ii1ing(s) and Hand
Delivered to the following:
Richard L. Horwitz, Esq.
Kenneth L, Dorsney, Esq.
Potter Anderson& Corroon LLP
Hercules Plaza, 6th Floor
l3l3 North Market Street
Wilmington, Delaware 19801
I hereby certify that on October 27, 2006, l have sent by U,S. Regular Mail, the foregoing
document to the following non~registered participants:
John W. Osborne, Esq.
Peter N. Fill, Esq.
Morgan & Finnegan, LLP
3 World Financial Center
New York, New York 10281-2101
K Q, gs @,.2%/
K. Tyler O'Conne1i (#4514)
Richards, Layton & Finger, P,A,
One Rodney Square
920 North King Street
Wilmington, Delaware 19801
(302) 651-7700
[email protected]
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