Free Motion to Intervene - District Court of Delaware - Delaware

Case 1 :04-cv-00910-GIVIS Document 217-17 Filed 04/20/2007 Page 1 of 2
IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF DELAWARE
)
INTEGRATED HEALTH SERVICES OF )
CLIFF MANOR, INC., INTEGRATED )
HEALTH SERVICES AT RIVERBEND, )
INTEGRATED HEALTH SERVICES AT )
SOMERSET VALLEY, INC., ALPINE )
MANOR, INC., BRIARCLIFF NURSH\IG )
HOME, INC., INTEGRATED HEALTH )
GROUP, INC., SPRING CREEK OF IHS, )
INC., FIRELANDS OF IHS, INC., ELM )
CREEK OF IHS, INC. and IHS LONG )
TERM CARE SERVICES, H\IC., )
)
Plaintiffs, )
)
v. ) Case No. 1:04-910-GMS
)
THCI COMPANY LLC, )
)
Defendant, )
)
and, )
)
ABE BRIARWOOD CORPORATION )
and JOHN DOES 1-10, )
)
Additional Counterclaim Defendants. )
)
APPLICATION BY PHARMERICA, INC. FOR ORAL ARGUMENT
OF ITS MOTION FOR INTERVENTION
In accordance with this Court’s procedures and Local Rule 7.1.4, Non-Party Intervenor
PharMerica, Inc. ("PharMerica"), by and through its undersigned attomeys, hereby respectfully
requests that this Court grant this application for oral argument of PharMerica’s Motion for
Intervention (the "Intervention Motion"), which was also respectfully submitted as a Response in
Opposition to the Motion by THCI Company, LLC ("THCI") To Enforce the Stipulation and
Order of Settlement and Dismissal (the "Enforcement Motion") [Docket No. 206].

Case 1 :04-cv-00910-GIVIS Document 217-17 Filed 04/20/2007 Page 2 of 2
PharMerica respectfully requests that oral argument be held on the Intervention Motion at
the Court’s earliest convenience, because PharMerica is being irreparably harmed unless
intervention is granted.
Dated: April 20, 2007 ARCHER & GREINER, P.C.
Wilmington, Delaware
By: s/ Peter L. Frattarelli
Peter L. Frattarelli (No. 2871)
300 Delaware Avenue
Suite 1370
Wilmington, Delaware 19801
Tel: (302) 777-4350
Fax (302) 777-4352
Attorneys for Non-Party Intervenor PharMerica, Inc.
2625217vl
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NYC/329285.2