Free Stipulation to EXTEND Time - District Court of Delaware - Delaware

Case 1 :O4—cv—OO955-GI\/IS Document 86-2 Filed O4/27/2007 Page 1 of 1 _
PRICKETT, JONES & ELL10TT
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April 27, 2007
VIA ELECTRONIC FILING
Honorable Gregory M. Sleet
United States District Court for the
District of Delaware
J. Caleb Boggs Federal Building
844 N. King Street, Room 4324
Lockbox 19
Wilmington, DE 19801
RE: Dennis J. Buckley, as Trustee 0f the DVI Liquidating
Trust v. Michael A. O’Hanl0n
C.A. N0. 04-955 {GMS)
Dear Judge Sleet:
Our office is Delaware cotmsel to Richard E. Miller in the above matter. Attached is a
Stipulation To Extend Time to answer Plaintiff’ s Complaint, which has been executed by all
counsel.
By way of background, on August 19, 2004 the Official Committee of Unsecured
Creditors filed a Complaint which consists of 247 separately numbered factual averments,
alleging massive fraud on the part of DV1’s officers and directors. All defendants responded to
the Complaint with motions to dismiss.
On March 28, 2007 the Court issued an opinion and an attached order which granted in
part and denied in part those motions to dismiss. Under Fed.R.Civ. P. l2(a)(4)(B), defendants
were required to answer the Complaint within ten days of the Court’s ruling. Due to the
voltuninous nature of the complaint, and the passage of time from when Defendants last
analyzed the Complaint for purposes of the motions to dismiss, defendants requested and were
granted an extension to answer the Complaint until May 7, 2007.
Based upon the foregoing, Defendants respectfully request that the Court grant the
extension provided for in the attached stipulation.
David E. Brand, Esquire
Bar ID No. 201
cc: All counsel listed on the Attached Stipulation
Enc.