Free Stipulation - District Court of Delaware - Delaware

Case 1:04—cv—00175-JJF Document 162 Filed 06/27/2008 Page 1 of 3
IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF DELAWARE
JOSEPH LAWRENCE CURRY, l)
)
Plaintiff, )
) Civil Action No. 04-175 ~J JF
v. )
)
)
GREGORY HOPKINS, )
)
Y Defendant. )
STIPULATION TO AMEND THE SCHEDULING ORDER,
EXTENSION OF TIME FOR RESPONSES TO PENDING MOTIONS AND
I REQUEST RULE 16 SCHEDULING CONFERENCE
;.. By order of March 25, 2008, this Court set a deadline of June 25, 2008, for the conduct of
fact discovery by Plaintiff (D.I. 142). On June 16, 2008, Plaintiff filed a Motion to Compel
under Rule 45 (D.l. 158) and on June 20, 2008, Plaintiff filed a Motion for Relief under Rule 37
(D.I. 160), each pertaining to outstanding discovery requests. Since that time, the parties have
conferred and reached an agreement on the matters in dispute, and accordingly stipulate to an
extension of the time for fact discovery to August 15, 2008. Should Defendant produce l
responses to all outstanding discovery requests by that time, Plaintiff shall withdraw the
aforesaid motions. The parties further stipulate that, if then necessary, the Defendant’s responses
to the aforesaid motions shall be filed by August 18, 2008 and Plaintiffs replies shall be filed by
August 25, 2008. Finally, the parties respectfully request a Rule 16 Scheduling Conference with

Case 1 :04-cv-00175-JJF Document 162 Filed 06/27/2008 Page 2 of 3
the Court at the Court’s convenience to advance resolution of this case, and respectfully request
that the Court grant this stipulation.
Dated: June 27, 2008 Respectfully submitted,
/s/ Daniel Grigzth /s/ Scott E. Swenson
Daniel A. Grifith (ID No. 4209) Scott E. Swenson (#4766) .
WHITEFORD TAYLOR & PRESTON Brian R. Lemon (#4730)
1220 North Market Street CONNOLLY BOVE LODGE & I-IUTZ LLP
Suite 608 The Nemours Building
Wilmington, DE 19801 1007 N. Orange Street
Phone: (302) 482-8754 Wilmington, DE 19801
Attorney for Defendant Phone: (302) 65 8-9141
Attorneys for Plaintyf
WHEREAS the Court, for good cause shown, hereby grants the parties’ foregoing
stipulation, and NOW THEREFORE, IT IS ORDERED THAT:
1. The deadline for the completion of fact discovery is extended from June 25, 2008
to August 15, 2008;
2. The Defendant’s responses to the Plaintiff s pending motions (D.I. 158, 160) shall
be filed by August 18, 2008 and Plaintiff s replies thereto shall be filed by August 25, 2008.
3. A Rule 16 Scheduling Conference shall be held by teleconference
, 2008, at .
U.S. District Court Judge Joseph J. Farnan

Case 1 :04-cv-00175-JJF Document 162 Filed 06/27/2008 Page 3 of 3
CERTIFICATE OF SERVICE
I, Scott E. Swenson, hereby certify that on June 27, 2008, I caused to be electronically
filed a true and correct copy of the foregoing document with the Clerk of the Court using
CM/ECF, which will send notiiication that such filing is available for viewing and downloading
to registered counsel of record via e—mail.
I hereby further certify that on June 27, 2008, I caused a copy of the foregoing document
to be served on the following counsel of record by the manner so indicated:
( VIA FACSINHLE ·
Da11iel A. Griffith, Esquire
Whiteford, Taylor & Preston
1220 N. Market Street
Suite 608
Wihnington, DE 19801
/s/ Scott E. Swenson
Scott E. Swenson (#4766)
3

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