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

Case 1:07-cv-00426-GMS

Document 31

Filed 01/29/2008

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IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF DELAWARE KENNETH J. MARINO, Plaintiff, v. CROSS COUNTRY BANK and APPLIED CARD SYSTEMS, INC., Defendants. STIPULATED ORDER EXTENDING TIME WHEREAS, by agreed Rule 16 Scheduling Order (D.I. 30) entered by the Court on December 20, 2007, the Court set the deadline for the parties to exchange pre-discovery disclosures as January 31, 2008; WHEREAS, on January 24, 2008, the parties engaged in a media tion session in the Appellate Mediation Program for the United States Court of Appeals for the Third Circuit and in which mediation the parties are attempting to reach a global resolution of all disputes between the parties, including this action; WHEREAS, a possible global resolution is being considered by the plaintiff, Kenneth J. Marino, who will be providing a response to the Third Circuit mediator on or before January 31, 2008; WHEREAS, the parties desire to avoid the expense of preparing pre-discove ry disclosures that will be unnecessary if a global resolution of all disputes is reached through the Third Circuit mediation; WHEREAS, a brief extension of the deadline to exchange pre-discovery disclosures will not affect the remainder of the deadlines in the Rule 16 Scheduling Order. C.A. No. 07-426-JJF

Case 1:07-cv-00426-GMS

Document 31

Filed 01/29/2008

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THEREFORE, the parties stipulate, subject to approval of the Court, that the deadline to exchange pre-discovery disclosures pursuant to Fed. R. Civ. P. 26(a)(1) and D. Del. LR 16.2 shall be extended until February 21, 2008.

GIBSON & PERKINS, P.C.

OBERLY, JENNINGS & RHODUNDA, P.A.

/s/ Kevin W. Gibson Kevin W. Gibson (No. 2025) 1326 King Street Wilmington, DE 19801 610-565-1708 ­ Telephone 610-565-4358 ­ Facsimile [email protected]

/s/ Karen V. Sullivan Charles M. Oberly, III (No. 743) Karen V. Sullivan (No. 3872) 1220 Market Street, Suite 710 P.O. Box 2054 Wilmington, DE 19899-2054 302-576-2000 ­ Telephone 302-576-2004 ­ Facsimile [email protected] [email protected]

It is SO ORDERED this _____ day of _______________________, 2008.

United States District Judge

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Case 1:07-cv-00426-GMS

Document 31-2

Filed 01/29/2008

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