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UNITED STATES DISTRICT COURT 2 n `‘’' ‘·‘ `
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JULIE DILLON RIPLEY MILLER, . (€g[UJ—§`(jDFM)
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Plaintiff and Counterclaim
Defendant,
- against —
MERRILL LYNCH CREDIT CORPORATION, _
April 23, 2004
Defendant and Connterclaimant.
DEFENDANT’S MOTION TO1 AMEND THE SCHEDULE APPLICABLE T0
DEFENDAN'I"S APPLICATION FOR PREJUDGMENT REMEDY
In furtherance of the efficient administration of this proceeding, Defendant brings
this Motion to Amend the Schedule Applicable to Defendant’s Application for Prejudgment
Remedy (the "Moti_on to Amendâ€). Plaintiff consents to the granting of this Motion.
This is the first motion to amend the schedule applicable to Defendant’s
EQ application for prejudgment remedy. Importantly, Defendant is not seeking to extend the dates
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E} _ set by the Court for adjudication of Defendant’s Application for Prejudgment Remedy
Q ("Defendant’s Application") — May 6, 20, 21 and 25, 2004. Rather, for the following reasons,
gl _ there is good cause to extend certain pre—hearing dates which will not impact the aforementioned
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·-\gl _ . 3 P- First, the parties are currently seeking to negotiate a Stipulation which would
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E`. Q eli1ginat@l1cgneed for any hearing on Defendant’s Application for Prejudgment Remedy. These
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