Free Motion for Extension of Time to File - District Court of Delaware - Delaware

Case 1 :O4—cv—O1474-JJF Document 11 Filed O3/07/2005 Page 1 of 2
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Christopher D. Loizides II King Slregll Suite Christopher D. Loizides
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March 7, 2005
VIA HAND DELIVERY AND ECF FILING
The Honorable Joseph J . Farnan
US District Court for the District of Delaware
844 N. King Street
Room 6124, Lockbox 27
Wilmington, DE 19801
Re: Michael Pope et al. v. Baron & Budd PC, etal, Appeal No. 1474
Dear Judge Farnan:
I am Delaware counsel to the appellants in the above-appeal. I write to request a
three—week extension of the deadline for the appellants to filo their opening brief in this
matter. Appellants requested the debtors’ agreement to an extension last week and the
debtors have taken this request under advisement. Due to the impending deadline, I felt it
necessary to make this request at this time.
The reasons for this request are most unfortunate. On the morning of February
28, appellants’ lead counsel, Joseph Pope, passed away uxexpectedly. Having appeared
with Mr. Pope in Court just a few weeks ago when he seemed in perfect health, this was
certainly a shock for me and everyone else who knew him.
Mr. Pope was one of two partners at the firm of Cohen Pope. The other partner,
Mr. Cohen, does not generally practice in litigation, has had no involvement in this
appeal and virtually none in the underlying bankruptcy. Cohen Pope also has three
associates, each of whom has had only limited involvement in this matter and are under
pressure to adress many other pressing matters. As for my firm, we are serving only in a
local capacity.
Due to these circumstances, appellants request a three-week extension of the
deadline to file their opening brief.
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Case 1 :O4—cv—O1474-JJF Document 11 Filed O3/07/2005 Page 2 of 2
I thank Your Honor for the Court’s consideration in this matter.
Respectfully,
D DA.jLoizides
CDL: l C (
Cc: Laura Davis Jones, Esq. (via telecopier)
Curtis Hehn, Esq. (via telecopier)
Daniel K. Hogan, Esq. (via telecopier)
O50307l5220l.DOCltr