Free Motion for Extension of Time to Complete Discovery - District Court of Delaware - Delaware

Case 1:04-cv-00370-SLR

Document 39

Filed 12/01/2006

Page 1 of 2

IN THE UNITED STATES DISTRICT COURT IN AND FOR THE DISTRICT OF DELAWARE JOHN DOHERTY, Plaintiff, v. NOREEN RENARD, JOSEPH PAESANI, JAMES LUPINETTI, MICHAEL TIGUE and ROBERT I. GEORGE, JR., Defendants. : : : : : : : : : : : :

C.A. No. 04-370-SLR

JOINT MOTION TO EXTEND DISCOVERY The parties move the Court to enter an order extending discovery from December 4, 2006 to December 18, 2006. In support of this motion, the following is shown: 1. The parties are presently engaged in discovery and settlement

negotiations. A number of depositions can not be scheduled until after the present discovery deadline of December 4, 2006. 2. If the discovery deadline were extended to December 18, 2006, that

would permit continued settlement negotiations and possibly vitiate the expense and need for additional depositions. Mediation is presently scheduled for January 2007. 3. The extension of the discovery deadline would not adversely affect

any other proceedings in this matter.

Case 1:04-cv-00370-SLR

Document 39

Filed 12/01/2006

Page 2 of 2

FOR THE PLAINTIFF:

FOR THE DEFENDANTS:

/s/ Richard R. Wier Richard R. Wier, Jr. Esquire Two Mill Road, Suite 200 Wilmington, DE 19806 (302) 888-3222 [email protected] DATED: December 1, 2006

/s/ Marc P. Niedzielski Marc P. Niedzielski Deputy Attorney General 820 N. French Street, 6th Floor Wilmington, DE 19801 (302) 577-8324 [email protected]

IT IS SO ORDERED this

day of December, 2006

that the scheduling order is hereby amended and the discovery deadline is extended to December 18, 2006.

________________________________ Chief United States District Judge