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

E Case 1 :04-cv-01549-JHR Document 20 Filed 06/30/2005 Page 1 of 3
IN THE UNITED STATES DISTRICT COURT in-
FOR THE DISTRICT OF DELAWARE
FARLOC ARGENTINA S.A., ) Hon. Joseph H. Rodriguez
Appellant, l Civil Action No. 04-1549
v. I On Appeal from an Order ofthe l
) United States Bankruptcy Court
FEDERAL—MOGUL GLOBAL INC. ) for the District of Delaware in
T&N LIMITED, et al. ) Bankruptcy Case No. 01-10578
Appellees. I _
STIPULATION BETWEEN THE DEBTORS AND FARLOC ARGENTINA S. A. 2
EXTENDING BRIEFING SCHEDULE
Federal-Mogul Global Inc., T&N Limited, etal. (collectively, the "Debtors") and
Farloc Argentina S. A. ("FarIoc") hereby stipulate (the "Stipulation”) as follows:
WHEREAS, on October 1, 2001, the Debtors commenced their chapter ll cases
by tiling voluntary petitions for relief under title ll of the United States Code (as amended, the
"Bankruptcy Code");
· WI-IEREAS, on November 17, 2004, the United States Bankruptcy Court for the '
District of Delaware (the “Banl Motion for Order Approving and Authorizing Rejection of Licensing Agreement with Farloc E
Argentina S.A. (Bankruptcy Docket No. 6373); _
WI—IEREAS, on November 24, 2004 Farloc filed its Notice of Appeal in
connection with the Order (Docket No. 6461);
' WHEREAS on December 24 , 2004, the Notice of Appeal was docketed in the
United States District Court for the District of Delaware (the "Dis1:rict Court"); l
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Case 1 :04-cv-01549-JHR Document 20 Filed 06/30/2005 Page 2 of 3
WHEREAS, pursuant to a District Court Standing Order dated July 23, 2004, all I
appeals from the Bankruptcy Court to the District Court were referred to mediation and briefing
was suspended for all such appeals;
WHEREAS, on January 6, 2005 Farloc filed its Brief and Appendix; -
WHEREAS, on January 14, 2005 the Court entered an Amended Notice of
Docketing indicating that the briefing schedule was no longer deferred and giving the Debtors
until January 27, 2005 to file their answering brief; p
WHEREAS, the parties hereto have discussed th briefing schedule and agreed
upon a schedule; and
WHEREAS, the parties hereto had previously agreed to extend the briefing
schedules in the above-captioned appeal to allow the Debtors to tile their answering brief no later
than July l, 2005 and Farloc to file its reply brief no later than July 15, 2005.
NOW TI·lER.EFORE,in consideration of the foregoing, and subject to the
approval ofthe Court, it is hereby stipulated and agreed by and between the Debtors and Farloc
as follows: i
l. Notwithstanding Fed.R.Bankr.P. 8009, the answering briefs, and the reply
briefs for the above captioned appeal shall be tiled according to the following schedule: 5
a. The Debtors shall file their answering brief on or before August l,
2005; and
b. Farloc shall file its reply brief on or before August 15, 2005. E
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Case 1 :04-cv-01549-JHR Document 20 Filed 06/30/2005 Page 3 of 3 _
2. Notwithstanding entry of the order, and in consideration ofthe extension
of the briefing schedule provided herein, the Debtors agree not to ten11inate the Licensing
Agreement that was the subject of the Order through and including August 1, 2005. i
3. The deadlines set forth herein may be extended by order ofthe Court. U-
SIDLEY AUSTIN BROWN & WOOD LLP BUCHANAN INGERSOLL P.C.
James F. Conlan
Larry J. Nyhan t
Kevin T. Lantry v. _ l
Kenneth P. Kansa David E. Wilks (Bar No. 2793) .
Bank One Plaza The Nemours Building I
10 South Dearborn Street 1007 North Orange Street, Suite 1110 .
Chicago, Illinois 60603 Wilmington, DE 19801-1236 ~
Telephone: (312) 853-7000 Telephone: (302) 428-5500
-ar1d- Attomeys for Farloc Argentina S. A.
PACHULSKJ, STANG, ZIEI-IL, YOUNG, JONES
& WEINTRAUB P.C.
Davis Jones (Bar No. 2436) _
J es E. O’Neill (Bar No. 4042)
9l9 North Market Street, 16m Floor
P.O. Box 8705 I
Wilmington, Delaware 19899-8705 (Courier 19801) . 5
Telephone: (302) 652-4100
Facsimile: (302) 652-4400
Attomeys for Debtors and Debtors-·in-Possession
IT IS SO ORDERED this day of
, 2005.
E
United States District Judge
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