Case 1:06-cv-00001-GMS
Document 13
Filed 06/22/2006
Page 1 of 2
IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF DELAWARE JAMES W. RILEY, PLAINTIFF, V. STANLEY TAYLOR, THOMAS CARROLL, DAVID PIERCE, AMY MUNSON, MEDICAL ASSISTANT MALANEY, CORRECTIONAL MEDICAL SYSTEMS and FIRST CORRECTIONAL MEDICAL, DEFENDANTS. ) ) ) ) ) ) ) ) ) ) ) ) ) )
CIVIL ACTION NO. 06-001 GMS TRIAL BY JURY DEMANDED
MOTION OF DEFENDANTS, MEDICAL ASSISTANT MALANEY AND CORRECTIONAL MEDICAL SERVICES, INC., FOR AN EXTENSION OF TIME TO RESPOND TO PLAINTIFF'S COMPLAINT Defendants, Medical Assistant Malaney and Correctional Medical Services, Inc. ("CMS"), improperly named Correctional Medical Systems, through their undersigned counsel, hereby move this Honorable Court to enter the attached Order, granting them an extension of time until July 30, 2006 in which to respond to plaintiff's Complaint and, in support thereof, aver as follows: 1. A Waiver of Service was returned executed by Defendant, CMS, on June 19,
2006. However, because Medical Assistant Malaney is no longer an employee of CMS, a waiver has not been executed on her behalf at this time. 2. Because of the nature of the allegations in Plaintiff's Complaint, the undersigned
defense counsel requires additional time to obtain and review Plaintiff's medical records in order to respond to Plaintiff's Complaint.
Case 1:06-cv-00001-GMS
Document 13
Filed 06/22/2006
Page 2 of 2
WHEREFORE, Defendants, Medical Assistant Malaney and Correctional Medical Service, respectfully move this Honorable Court to enter the attached Order, granting them an extension of time until July 30, 2006 in which to respond to Plaintiff's Complaint.
MARSHALL, DENNEHEY, WARNER, COLEMAN & GOGGIN
BY:
/s/ Kevin J. Connors KEVIN J. CONNORS, ESQ. DE Bar ID: 2135 1220 North Market Street, 5th Fl. P.O. Box 8888 Wilmington, DE 19899-8888 Attorney for Defendants, Medical Assistant Malaney and Correctional Medical Services, Inc.
DATED: June 22, 2006
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