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