Case 1:04-cv-01200-SLR
Document 16
Filed 03/30/2005
Page 1 of 5
IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF DELAWARE RUSSELL STEWART, Plaintiffs, v. STATE OF DELAWARE, DEPARTMENT OF PUBLIC SAFETY, CAPITOL POLICE, Defendant ) ) ) ) ) ) ) ) ) ) )
Civ. No. 04-1200-SLR
NOTICE OF MOTION PLEASE TAKE NOTICE that the undersigned attorney will present the attached Motion to Request a New Scheduling Order at a time convenient to Court and Counsel.
/s/ R. Stokes Nolte R. Stokes Nolte, Esquire De. State Bar I.D. No.: 2301 Nolte & Associates 1010 N. Bancroft Parkway Suite 21 Wilmington, DE 19805 (302) 777-1700 Attorney for Russell Stewart Date:
Case 1:04-cv-01200-SLR
Document 16
Filed 03/30/2005
Page 2 of 5
IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF DELAWARE
RUSSELL STEWART, Plaintiff, v. STATE OF DELAWARE, DEPARTMENT OF PUBLIC SAFETY, CAPITOL POLICE Defendant.
) ) ) ) ) ) ) ) ) ) )
Civ. No. 04-1200-SLR
MOTION TO REQUEST A NEW SCHEDULING ORDER COMES NOW, Russell Stewart, plaintiff by and through his attorney, R. Stokes Nolte, and files this motion to request a new scheduling order, and as grounds therefor shows:
1.
Plaintiff retained attorney's services on Friday, March 11, 2005, prior to that
plaintiff was unrepresented.
2.
The Honorable Court entered a scheduling order in this matter in November 2004.
That order contains a discovery cut off of March 31, 2005.
3.
In order to allow Plaintiff's attorney to adequately prepare discovery in the case,
and allow time to respond to defendant's discovery, Plaintiff requests a new scheduling order.
Case 1:04-cv-01200-SLR
Document 16
Filed 03/30/2005
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WHEREFORE, Movant requests that the Court, after due notice and hearing, order a new scheduling order.
/s/ R. Stokes Nolte R. Stokes Nolte, Esquire De. State Bar I.D. No.: 2301 Nolte & Associates 1010 N. Bancroft Parkway Suite 21 Wilmington, DE 19805 (302) 777-1700 Attorney for Russell Stewart Date: 3/30/05
Case 1:04-cv-01200-SLR
Document 16
Filed 03/30/2005
Page 4 of 5
IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF DELAWARE RUSSELL STEWART, Plaintiff, v. STATE OF DELAWARE, DEPARTMENT OF PUBLIC SAFETY, CAPITOL POLICE Defendant. ) ) ) ) ) ) ) ) ) ) )
Civ. No. 04-1200-SLR
ORDER ON THIS the ______________________day of ______________________, 2005, having considered the above motion IT IS ORDERED that: 1. The above motion is granted and the following scheduling order is issued:
SIGNED this ___________ day of __________________________
_________________________ J.
Case 1:04-cv-01200-SLR
Document 16
Filed 03/30/2005
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