Free Motion for Miscellaneous Relief - District Court of Delaware - Delaware

Case 1 :04-cv-00414-SLR Document 94 Filed 04/10/2008 Page 1 of 2
IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF DELAWARE
WILLIE DAVIS, IR., etal., : .
Plaintiffs, ;
v. ; Civil No O4-414-SLR
MOUNTAIRE FARMS, INC., et al., ;
Defendants. Z
/
UNOPPOSED MOTION 'I"0 CHANGE TRIAL DATE
Defendants respectfully move to change the trial date in this case from the week
of August ll, 2008, to the week of August 4, 2008. The case was scheduled for trial
during a telephone conference on March 18, 2008, and confirmed by Order entered that
day. D.l. 9l. At that time, one of Defendants’ counsel, Eric Hennnendiriger, was
unaware that his wife had scheduled and prepaid a family vacation for the week of
August ll, 2008.1 Mr. Hemmendinger has worked extensively with Mountaire Farms
and has participated in preparation of this case. He has over thirty years experience in the
defense of labor litigation, with an emphasis on Fair Labor Standards Act cases.
Counsel for Defendants has reviewed this request with counsel for flaintiffs who
has authorized the undersigned to state that Plaintiffs’ counsel does not oppose this
motion provided the trial is rescheduled in August. The only mutually available date is
the week of August 4, 2008. Therefore, with apologies to the Court for any
‘ Mr. Hemmendinger has tried to reschedule the vacation, however, it turned out to be
impossible due to his daughters’ prior commitments.

Case 1:04-cv-00414-SLR Document 94 Filed 04/10/2008 Page 2 of 2
inconvenience caused, Defendants respectfully request a change of trial date as indicated
inthe attached form of order.
espectfully submitted,
Matthew F. Boyer (D . Bar No. 56-4)
CONNOLLY BOVE LODGE & HUTZ, LLP
The Nemours Building
1007 N. Orange Street
P. O. Box 2207
Wilmington, DE 19899
(302) 884-·6S85
Arthur M. Brewer (admitted Pro Hee Vice)
Eric Hemmendinger (admitted Pro Hac Vice)
SHAWE & ROSENTHAL, LLP
Sun Life Building, llth Floor
20 S. Charles Street
Baltimore, MD 21201
(410)752~1040
2

Case 1:04-cv-00414-SLR

Document 94

Filed 04/10/2008

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Case 1:04-cv-00414-SLR

Document 94

Filed 04/10/2008

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