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

Case 1:08-cv-00003-GMS

Document 6

Filed 02/01/2008

Page 1 of 2

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF DELAWARE MEHMET AKSOY, Plaintiff, v. SELECTRUCKS OF AMERICA, LLC, Defendant. : : : : : : : : :

C.A. No. 08-003 (GMS)

JURY TRIAL DEMANDED

AMENDED 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 January 23, 2008 to February 8, 2008; WHEREAS, for the Defendant, the basis for the request is that defense counsel was retained in this matter on January 16, 2008 and, prior to said retention, was scheduled to participate in multiple depositions in a complex construction case involving numerous defendants pending in the Delaware Superior Court on January 21, 22, 23, 24 and 25, 2008. Defense counsel requires additional time in which to consult with her client and to obtain the information necessary to properly respond to the allegations set forth in Plaintiff's Complaint. WHEREAS, defense counsel is unassisted by other attorneys in both the aforementioned case and the instant action; WHEREAS, counsel for the Plaintiff has no opposition to Defendant's request for an extension of time in which to respond to the Complaint.

Case 1:08-cv-00003-GMS

Document 6

Filed 02/01/2008

Page 2 of 2

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 8, 2008. FERRY, JOSEPH & PEARCE, P.A. MARSHALL, DENNEHEY, WARNER, COLEMAN & GOGGIN BY: /s/ Tracy A. Burleigh TRACY A. BURLEIGH, ESQUIRE I.D. No. 3609 1220 North Market Street, 5th Floor P.O. Box 8888 Wilmington, DE 19899 (302) 552-4304 Attorney for Defendant, SelecTrucks of America, LLC Dated: 02/01/08

BY:

/s/ Rick S. Miller RICK S. MILLER, ESQUIRE I.D. No. 3418 824 Market Street, Suite 904 P.O. Box 1351 Wilmington, DE 19899 (302) 575-1555 Attorney for Plaintiff, Mehmet Aksoy

Dated: 02/01/08

SO ORDERED this

of

, 2008.

J.
06215-102/15/579347.v1