Free Notice (Other) - District Court of Delaware - Delaware

Case 1:04-cv—01026—KAJ Document 38 Filed 02/07/2006 Page 1 of 2
IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF DELAWARE
In re:
NationsRent, Inc, et al., Case Nos. 01-1 1628 through 01-11639 (PJW')
Jointly Administered
Debtors. Chapter 11
NationsRent Unsecured Creditors’
Liquidating Trust, Perry Mandarino, not
personally, but as Trustee
Plaintiff Case No. 04—CV—1026 (KAJ)
v.
Bobcat Company,
Defendant.
CERTIFICATION OF COUNSEL
REGARDING SCHEDULIN G ORDER
I, Ashley B. Stitzer, Esquire, counsel for Perry Mandarino, Trustee of the
NationsRent Unsecured Creditors’ Trust (the "Trustee"), hereby certify the following:
1. On December 15, 2005, the Trustee filed the Motion for Leave to Amend
Complaint (the "Motion") and the Memorandum of Law in support of Motion.
2. On December 23, 2005, the Defendants! tiled the Objection to Motion of
Trustee for Leave to Amend Complaint and Motion to Dismiss (the "Motion to
Dismiss").
3. On or about January 6, 2006, the parties completed briefing relating to the
Motion and the Motion to Dismiss.
I Tenns not otherwise deiined herein shall have the meaning ascribed to them in the Motion.
577822vI

Case 1:04-cv—01026—KAJ Document 38 Filed 02/07/2006 Page 2 of 2
4. On or about January 13, 2006, the Court entered the Order scheduling a
hearing on February 1, 2006 (the "Hearing”) for oral argument regarding the Motion and
the Motion to Dismiss,
5. At the Hearing, the parties resolved amicably the Motion and the Motion
to Dismiss and agreed to, inter alia, extend certain discovery deadlines set in the
Scheduling Order entered by the Court on October 18, 2005,
6, Attached hereto as Exhibit A is a proposed Scheduling Order (the
Proposed Scheduling Order") that extends fact and expert discovery deadlines through
June 1, 2006. The Defendants have agreed to the proposed deadlines provided in the
Proposed Scheduling Order
WHEREFORE, I respectfully request that the Court enter the Proposed
Scheduling Order at its earliest convenience
Dated; February 7, 2006 THE BAYARD FIRM
1 g
4{.1_ Q
eil B, Glass an, Esq, (No, 2 87)
Ashley B. er (No. 3891)
Mary E. A ; stine (No. 4
222 Delaware Avenue, Suite 900
Wilmington, Delaware 19801
Telephone: (302) 655-5000
Attorneys for Perry Mandarino,
Trustee ofthe NationsRent Unsecured
Creditors’ Liquidating Trust
577822vl 2