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

Case 1:04-cv-00904-KAJ

Document 140

Filed 11/18/2005

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IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF DELAWARE W.C. HERAEUS GMBH (a German corporation), ) and HERAEUS INCORPORATED (a Delaware ) corporation) ) ) Plaintiffs, ) ) v. ) ) MARJORIE JOY LYNN as Personal Representative) for the ESTATE OF DAVID MARK LYNN and as ) Trustee of the MARK AND MARJORIE LYNN ) REVOCABLE TRUST, LYNN PLASMA, INC. ) (an Idaho corporation), NXEDGE, INC. ) (a Delaware corporation), and NXEDGE INC. OF ) BOISE (a Delaware corporation) ) ) Defendants. )

C.A. No. 04-904 (KAJ)

JOINT STIPULATION AND ORDER EXTENDING DAMAGES EXPERT DEADLINES To permit the parties further time to prepare and exchange damages expert disclosures, plaintiffs W.C. Heraeus GmbH and Heraeus Inc. (collectively, "Plaintiffs") and the defendants, Marjorie Joy Lynn (as personal representative for the Estate of David Mark Lynn and as Trustee of the Mark and Marjorie Lynn Revocable Trust), Lynn Plasma, Inc., NxEdge, Inc. and NxEdge Inc. of Boise (collectively, "Defendants") stipulate, subject to the approval of the Court, to extend the following deadlines set by this Court in its January 23, 2005 Order (D.I. 105) and October 13, 2005 Order (D.I. 120) as follows: 1. The parties shall serve their initial Federal Rule of Civil Procedure

26(a)(2) disclosures of damages expert testimony on or before Friday, December 16, 2005. (The deadline to serve these disclosures is currently set for Wednesday, November 23, 2005).

Case 1:04-cv-00904-KAJ

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2.

The parties shall serve their supplemental damages disclosures to

contradict or rebut evidence on the same subject matter identified by another party on or before Thursday, January 23, 2006. (The deadline to file these disclosures is currently set for Friday, December 23, 2005). 3. The deadline by which the parties shall complete damages expert

depositions shall be Friday, February 17, 2006. (The deadline to complete expert depositions is currently set for Wednesday, January 18, 2006). 4. These extensions shall not affect any of the other existing deadlines in this

case, including the deadlines for non-damages related expert discovery, fact discovery, or case dispositive motions.

CONNOLLY BOVE LODGE & HUTZ /s Kevin M. Baird Kevin M. Baird (#4219) [email protected] The Nemours Building 1007 North Orange Street P.O. Box 2207 Wilmington, DE 19801 (302) 252-4234 Attorneys for Defendants Marjorie Joy Lynn as personal representative for the Estate of David Mark Lynn and as Trustee of the Mark and Marjorie Lynn Revocable Trust, Lynn Plasma, Inc., NxEdge, Inc. and NxEdge, Inc. of Boise

MORRIS, NICHOLS, ARSHT & TUNNELL /s Karen Jacobs Louden Karen Jacobs Louden (#2881) [email protected] Leslie A. Polizoti (#4299) 1201 N. Market Street P.O. Box 1347 Wilmington, DE 19899-1347 (302) 658-9200 Attorneys for Plaintiffs W.C. Heraeus GmbH and Heraeus Incorporated

IT IS SO ORDERED.

Dated:

_____________, 2005

Kent A. Jordan UNITED STATES DISTRICT JUDGE

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