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

Case 1 :07-cv-00675—GIV|S-LPS Document 47 Filed 05/12/2008 Page 1 of 3 q
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A IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF DELAWARE
L.C. l et al., :
Plaintiffs, Case N0.: 07-675 GMS
‘ VS. JURY TRIAL DEMANDED
STATE OF DELAWARE, et al.,
Defendants `
STIPULA TION FOR EXTENSION OF TIME
IT IS STIPULATED by the parties, through their attorneys, subject to approval ofthe Court, that the
time for the Plaintiffs to respond to Defendant, Andrew Lippstone’s Motion to Dismiss Complaint, and
Defendants, State of Delaware, Delaware Division of Family Services, [Delaware] Department of Services
for children, Youth and their Families, and Marcia Tremper ("State Defendants") Motion to Dismiss
Complaint is hereby extended until June I6, 2008 for the following reasons:
I. Defendants, Andrew Lippstone and the State Defendants have filed Motions to Dismiss
Plaintiffs’ Complaint. By prior Stipulations the Plaintiffs° Answers to these motions are currently due on §
May I2, 2008.
2. By Order dated April 2, 2008, The Honorable Chief Judge Gregory M. Sleet granted the
Motion for the Pro Hac Vice appearance of J effrey P. I-Ioyle, Esquire as co—counsel for the Plaintiffs.
3. Plaintiffs request an extension ofthe time within which they must respond to the Defendants’
Motions to Dismiss so that their new counsel can complete his review of the case and Motions of the
Defendants.
4. Jeffrey P. Hoyle, Esquire has conferred with counsel for the moving Defendants, Collins J.
Seitz, Jr., Esquire and Deputy Attorney General Ralph Durstein, Esquire who both have agreed to the
extension requested herein.
5. Counsel for the Plaintiffs represent herein that the requested extension is made for the L
purposes of evaluating and answering the Motions of the Defendants and considering the arguments made

Case 1 :07-cv-00675—GIV|S-LPS Document 47 Filed 05/12/2008 Page 2 of 3
by the moving Defendants with a view to the voluntary dismissal of any party not properly subject to liability V
to the Plaintiffs. i
6. By letter dated April 29, 2008 Counsel for the Plaintiffs requested that this Honorable Court
hold a Rule 16 Scheduling Conference and in conjunction therewith that discoverable tiles, records and other l
materials in the Defendants’ possession be Ordered to be produced considering the rules and policies
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regarding confidentiality and non—disclosure of records of the type Defendants are being asked to produce
with respect to these minor children.
7. A Motion requesting this conference and a stay of proceedings will be tiled separate hereto.
SCHJVHDT, KJQRIFIDES, PEARSON, DEPARTMENT OF JUSTICE
KOUTCHER & FRIDKIN
/s/
Matthew H. Osborne, Esq. Bar #4630 /S/
1301 N. Harrison Street, Unit 105
Wilmington, DE 19806 Ralph Durstein, Esquire
(302) 83 6-3900 Deputy Attorney General
Attorneys for Plaintiffs Cawel State Office Building
820 North French Street
Dated: May 12, 2008 Wilmington, DE 19801
Attorney for State Defendants
CONNOLLY, BOVE, LODGE & HUTZ, LLP Dated: May 12, 2008
/s/
Collins J. Seitz, Jr., Esquire
Connolly, Bove, Lodge & Hutz, LLP _
1007 North Orange Street l
PO Box 2207
Wilmington, DE l9899
Attorney for Defendant Lippstone
Dated: May l2, 2008
SO ORDERED this day of , 2008.
United States District Judge

Case 1 :07-cv-00675—GIV|S-LPS Document 47 Filed 05/12/2008 Page 3 of 3 p
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CERTIFICATE OF MAILING AND/OR DELIVERY i
The undersigned certifies that on the 12th day of May, 2008, he caused the attached Stipulation for
Extension of Time to file Plaintiffs Answering Brief/Response to be filed with the Clerk of Court using
CM/ECP which will send notification of such filing(s) to the following:
` Name and Address of Recipie11t(s):
Stephani J. Ballard, Esquire Collins J. Seitz, Jr., Esquire
Deputy Attorney General Connolly, Bove, Lodge & Hutz, LLP ~
Carvel State Office Building 1007 North Orange Street
820 N. French Street, 6* Floor PO Box 2207
Wilmington, DE 19801 Wilmington, DE 19899
William J. Cattie, III, Esquire Ralph Durstein, Esquire
Rawle & Henderson, LLP Deputy Attorney General
300 Delaware Avenue, Suit 1015 Carvel State Office Building _
P.O. Box 588 820 North French Street
Wilmington, DE 19899-0588 Wilmington, DE 19801 A i
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Kevin J. Connors, Esquire
Marshall, Dennehey, Warner, Coleman & Goggin
P.O. Box 8888 F
Wilmington, DE 19801 S
SCHIVHDT, KIRIFIDES, PEARSON, KOUTCHER & FRIDKIN
Date: May 12, 2008 By /s/
Matthew H. Osborne, Esquire
1301 N. Harrison Street, Unit #105
Wilmington, DE 19806
(302) 836-3900
ID. No.: 4630
osbornelaw(@,verizon.net

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