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

Case 1:04-cv-00330-KAJ

Document 30

Filed 04/07/2005

Page 1 of 2

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF DELAWARE UNITED STATES OF AMERICA, Plaintiff, v. ELWOOD S. KNIGHT, MILDRED M. KNIGHT, and ELWOOD S. KNIGHT TRUSTEE OF THE KNIGHT 1995 IRREVOCABLE TRUST, Defendant. : : : : : : : : : : : :

Civil Action No. 04-330-KAJ

STIPULATION FOR EXTENSION OF DATES FOR DISCOVERY CUT-OFF The parties, through the undersigned counsel, hereby stipulate and agree, subject to the approval of the Court, that: 1. The discovery cut-off date is extended by thirty days, from April 8, 2005 to

April 22, 2005. 2 affected. 3. The parties seek this extension of time for the following reasons. Although the No other date set in the Court's Scheduling Order of November 17, 2004 will be

deposition of defendant Elwood Knight was anticipated to last several hours, Mr. Knight, as the caretaker of his spouse, unexpectedly had to leave the deposition to attend to her. 4. Further, at the deposition, Mr. Knight agreed to provide documents arguably

responsive to the government's earlier discovery requests, which had not yet been disclosed to the United States. The United States would like an opportunity to review the documents prior to the continuation of Mr. Knight's deposition.

Case 1:04-cv-00330-KAJ

Document 30

Filed 04/07/2005

Page 2 of 2

5.

Finally, several anticipated witnesses were unexpectedly unavailable for

deposition. The United States expects to complete all remaining depositions during the week of April 18, 2005. COLM F. CONNOLLY United States Attorney

/s/ Joseph J. Longobardi, III Joseph J. Longobardi, III, Esquire Delaware Bar I.D. No.2231 Longobardi Law Office The Plaza, Suite 115 1303 Delaware Avenue Wilmington, Delaware 19806 (302) 575-1502 [email protected]

BY:

/s/ Patricia C. Hannigan Patricia C. Hannigan Assistant United States Attorney Delaware Bar I.D. No.2145 The Nemours Building 1007 Orange Street, Suite 700 P. O. Box 2046 Wilmington, DE 19899-2046 (302) 573-6277 [email protected] For Plaintiff United States of America

For Defendants Elwood Knight, et al.

Date:

, 2005

Date:

, 2005

IT IS SO ORDERED this

day of

, 2005.

HONORABLE KENT A. JORDAN District Judge U.S. District Court