Free Motion for Extension of Time to File Response/Reply - District Court of Delaware - Delaware

Case 1:08-cv-00064-JJF

Document 3

Filed 02/04/2008

Page 1 of 2

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF DELAWARE MARIA MANIATAKIS, Plaintiff, v. OHIO CASUALTY GROUP and WEST AMERICAN INSURANCE COMPANY, Defendants. : : : : : : : : : : :

C.A. No. 08-64

TRIAL BY JURY OF TWELVE DEMANDED

STIPULATION TO EXTEND TIME FOR FILING RESPONSIVE PLEADING WHEREAS, the parties have respectfully requested that the Court consider an extension of the date by which Defendant's Answer to the Complaint is due in this action from February 6, 2008 to February 18, 2008; WHEREAS, the basis for the request for an extension of time is defense counsel requires additional time in which to receive, review and analyze the initial file materials from her client, to consult with her client and to obtain the information necessary to properly respond to the allegations set forth in Plaintiff's Complaint. WHEREAS, counsel for both parties have discussed such extension of time and counsel for the Plaintiff has no opposition to Defendant's request for an extension of time in which to respond to the Complaint. IT IS HEREBY STIPULATED by and between the parties, subject to the approval of the Court, that the date by which Defendant must file a responsive pleading in the above matter is extended until February 18, 2008.

Case 1:08-cv-00064-JJF

Document 3

Filed 02/04/2008

Page 2 of 2

BIGGS & BATTAGLIA

MARSHALL, DENNEHEY, WARNER, COLEMAN & GOGGIN BY: /s/ Vicki L. Goodman VICKI L. GOODMAN, ESQUIRE I.D. No. 4861 1220 North Market Street, 5th Floor P.O. Box 8888 Wilmington, DE 19899 (302) 552-4348 Attorney for Defendants, Ohio Casualty Group and West American Insurance Company Dated: 02/04/08

BY:

/s/ Robert D. Goldberg ROBERT D. GOLDBERG, ESQUIRE I.D. No. 631 921 N. Orange St. P.O. Box 1489 Wilmington, DE 19899 (302) 655-9677 Attorney for Plaintiff, Maria Maniatakis

Dated: 02/04/08

SO ORDERED this

of

, 2008.

J.
15/579760.v1

Case 1:08-cv-00064-JJF

Document 3-2

Filed 02/04/2008

Page 1 of 1

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF DELAWARE MARIA MANIATAKIS, Plaintiff, v. OHIO CASUALTY GROUP and WEST AMERICAN INSURANCE COMPANY, Defendants. : : : : : : : : : : :

C.A. No. 08-64

TRIAL BY JURY OF TWELVE DEMANDED

CERTIFICATE OF SERVICE I, Vicki L. Goodman, Esquire, hereby certify that a true and correct copy of the Stipulation to Extend Time for Filing Responsive Pleading were served on the below date via electronic filing, upon the following individuals: Robert D. Goldberg, Esquire Steven F. Mones, Esquire BIGGS AND BATTAGLIA 921 Orange Street Wilmington, DE 19801 Attorneys for Plaintiff MARSHALL, DENNEHEY, WARNER, COLEMAN & GOGGIN BY: _________________________________ VICKI L. GOODMAN, ESQUIRE (DE I.D. No. 4861) 1220 North Market Street, 5th Floor P.O. Box 8888 Wilmington, DE 19899 (302) 552-4348 Attorneys for Defendants Dated: February 4, 2008