Free Appendix - District Court of Delaware - Delaware

‘ Case 1:O4—cv-OO612—Gl\/IS Document 18-11 Filed O3/31/2005 Page 1 of 2
A ` FIL . _ 4.
cram us. DISTRICT u0l3.RT
_ ( _ IN THE UNITED STATES DISTRICT COURT Ell$IRlCT UF DELAWARE
FOR THE DISTRICT OF DELAWARE ‘ .· -
Z§§*•lJEC l3 Pl1_l•= 07 I
IN RE: INACOM CORP., et al. E ~ *
Inacom Corp., . ) _ ‘ E
)
‘ Plaintiff, ) Civil- Action No. 04-612 GMS _ _ _
. l I
i v. )
)
General Electric Company, ) ‘
, n · ) Advérsary Case No. 03-50501
Defendant. ) Bankruptcy Case No. 00-2426 PJW
STIPULATED CONTINUANCE OF SCHEDULING ORDER U l -·
The parties, by and through their undersigned counsel, hereby stipulate that the datefor
__ ` completion of discovery in the above-captioned matter should be extended ninety (90) days until
( .March 9, 2005. All other deadlines should be extended to accommodate this change. The "
n reasons for the deadlineextension are set forth belowr I I
_ ` _ 1. On September 13, 2004, Inacom served its Plaintiff’s First Set of Document
l Production Requests, P1aintiff’s First Set of Interrogatories to Defendant and Plaintiff’s Request
for Admission Propounded to Defendant, Set One. .
2. On September 22, 2004, the Court held a status conference and entered a -
scheduling order in this matter that set a discovery deadline of December 9, 2004 [D.I. 6].
3. The parties have conferred numerous times regarding Defendant’s response t0·
I discovery. Defendant has conducted a diligent search of its records and contacted numerous
g employees regarding this matter. Due to the passage of time and employee turnover, Defendant
has been unable to locate records or personnel with the requisite information and knowledge to _
U { _ respond to the discovery requests propounded by the Plaintiff. _
GE]C0ntinuance I

Case 1:04-cv-OO612—Gl\/IS Document 18-11 Filed O3/31/2005 Page 2 of 2
( - E . _ 4. Plaintiff noticed the deposition of the person most knowledgeable regarding the n
allegations set forth in the Complaint for December 2, 2004. However the parties were unable to L
proceed with the deposition because they have been unable to locate the person most
_ n knowledgeable. _ `
n 5. Plaintiff noticed and conducted the deposition of Larry Klein a former employee _
of the Defendant on December 3, 2004. Mr. Klein was unable to rec-all a majority of the
infomation requested by Plaintiff. U
. 6. Therefore, due to the parties’ desire to complete meaningful discovery prior to
participating in a trial on this matter, the parties respectfully request that the Court enter an order
extending the discovery deadline in this case until March 9, 2005 and adjust the remaining
_ l l deadlines set forth in the scheduling order to account for this extension. ‘
n r LANDIS RATH COBB LLP 1 I UPACHULS STANG, .- E HL, YOUNG,
_ . _ _- - , r . JONES : €$Eq;l · · !?£ /‘· ·g
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. mr-., .- _ § qyg l · A `
Daniel B. Rath, Esquire (#3022) Laura es (Bar No. 2436)
Rebecca L. Butcher, Esquire (#3816) Andrew . ' aine (CA Bar No. 110345)
919 Market Street, Suite 600 _ Jeffrey P. Nolan (CA Bar No. 158923)**
Wilmington, Delaware 19801 -· - 919 North Market Street, 16th Floor
(302) 467-4400 P.O. Box 8705
Wilmington, Delaware 19899-8705 .
Attorneys for Defendant Telephone: (302) 652-4100 _
_ Facsimile: (302) 652-4400 I
n Attomeys for Plaintiff J
SO ORDERED this day of December, 20_04. .
United States District Judge
1
GE Continuancc

Case 1:04-cv-00612-GMS

Document 18-11

Filed 03/31/2005

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Case 1:04-cv-00612-GMS

Document 18-11

Filed 03/31/2005

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