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

Case 1:04-cv-01254-GMS

Document 93

Filed 05/25/2006

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IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF DELAWARE

HARRY SMITH, JR. and ROSLYN WOODARD SMITH, Individually and as Administrators of The ESTATE OF HARRY SMITH, III, Plaintiffs, v. CITY OF WILMINGTON, JOHN CIRITELLA, in his individual capacity and in his official capacity as a police officer of the Wilmington Police Department, THOMAS DEMPSEY, in his individual capacity and in his official capacity as a police officer of the Wilmington Police Department, and MATHEW KURTEN, in his individual capacity and in his official capacity as a police officer of the Wilmington Police Department, Defendants. CIVIL ACTION NO. 04-1254-GMS

PLAINTIFFS' UNOPPOSED MOTION FOR ENLARGEMENT OF TIME TO COMPLETE DISCOVERY AND TO FILE EXPERT REPORTS AND CERTIFICATION OF COMPLIANCE WITH LOCAL RULE 7.1.1

Plaintiffs, by their counsel, hereby respectfully move this Honorable Court for the following order: 1) moving the date for the close of discovery (except expert witnesses) from May 31, 2006 to June 9, 2006; and 2) moving the date for expert reports from May 31, 2006 to June 30, 2006.

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Case 1:04-cv-01254-GMS

Document 93

Filed 05/25/2006

Page 2 of 3

All other scheduling order dates will remain the same.

As grounds for this motion, plaintiffs state: a) Plaintiffs' attorney Anne Sulton has discussed this motion with defense attorney John Parkins. He does not oppose this motion. b) Counsel for plaintiffs and defendants have been diligent, exchanging thousands of pages of documents, per numerous discovery requests, and are in the process of completing depositions. c) There is no prejudice to any party should the Court grant this motion. Respectfully submitted this 25th day of May 2006.

/s/Anne T. Sulton Anne T. Sulton Attorney for Plaintiffs Sulton Law Offices Post Office Box 2763 Olympia, WA 98507 Telephone: (609) 468-6029 E-mail: [email protected]

LOCAL COUNSEL: Kester I.H. Crosse Delaware State Bar I.D. #638 1214 King Street, Wilmington, DE 19801 Telephone: (302) 658-3488 E-Mail: [email protected]

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Case 1:04-cv-01254-GMS

Document 93

Filed 05/25/2006

Page 3 of 3

CERTIFICATE OF SERVICE I hereby certify that on May 25, 2006 I electronically filed the foregoing Plaintiffs' Motion with the Clerk of Court using CM/ECF which will send notification of such filing(s) to the following e-mail address: Attorney John Parkins: [email protected]

/s/Anne T. Sulton Anne T. Sulton Attorney for Plaintiffs Sulton Law Offices Post Office Box 2763 Olympia, WA 98507 Telephone: (609) 468-6029 E-Mail: [email protected]

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