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

Case 1 :04-cv-01549-JHR Document 18 Filed 05/19/2005 Page 1 of 3
IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF DELAWARE
FARLOC ARGENTINA S.A., ) Hon. Joseph H. Rodriguez
Appellant, g Civil Action No. 04-1549
v. ) On Appeal from an Order of the
) United States Bankruptcy Court
FEDERAL-MOGUL GLOBAL INC. ) for the District of Delaware in
T&N LIMITED, etal. ) Bankruptcy Case No. O1-10578
Appellees. )
STIPULATION BETWEEN THE DEBTORS AND FARLOC ARGENTINA S. A.
EXTENDING BRIEFING SCHEDULE
Federal-Mogul Global Inc., T&N Limited, et al. (collectively, the "Debt0rs") and
Farloc Argentina S. A. (“Farloc") hereby stipulate (the "Stipulation") as follows:
WHEREAS, on October I, 2001, the Debtors commenced their chapter 11 cases
by tiling voluntary petitions for relief under title 11 of the United States Code (as amended, the
"Bankruptcy Code");
WHEREAS, on November 17, 2004, the United States Bankruptcy Count for the
District of Delaware (the "Bankruptcy Court") entered an Order (the "Order") Granting Debt0rs'
Motion for Order Approving and Authorizing Rejection of Licensing Agreement with Farloc
Argentina S.A. (Bankruptcy Docket No. 6373);
WHEREAS, on November 24, 2004 F arloc filed its Notice of Appeal in
comiection 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 "District Court");
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A Case 1 :04-cv—01549-JHR Document 18 Filed 05/19/2005 Page 2 of 3
WHEREAS, pursuant to a Disttict Court Standing Order dated July 23, 2004, all
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 I4, 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;
WHEREAS, the parties hereto have discussed the 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 May 20, 2005 and Farloc to file its reply brief no later than June 3, 2005.
NOW THEREFORE, in consideration of the foregoing, and subject to the
approval of the Court, it is hereby stipulated and agreed by and between the Debtors and Farloc
as follows:
l. Notwithstanding Fed.R.Bankr.P. 8009, the answering briefs, and the reply
briefs for the above captioned appeal shall be filed according to the following schedule:
a. The Debtors shall file their answering brief on or before July l,
_ 2005; and
b. Farloc shall file its reply brief on or before July 15, 2005.
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Case 1 :04-cv—01549-JHR Document 18 Filed 05/19/2005 Page 3 of 3
2. Notwithstanding entry of the order, and in consideration ofthe extension
ofthe briefing schedule provided herein, the Debtors agree not to terminate the Licensing
Agreement that was the subject ofthe Order through and including July 1, 2005.
3. The deadlines set forth herein may be extended by order of the Court.
SIDLEY AUSTIN BROWN & WOOD LLP BUCHANAN INGERSOLL P.C.
James F. Conlan
Larry J. Nyhan r- C Q,
Kevin T. Lanny . \ · "
Kenneth P. Kansa David E. Wilks (Bar No. 2793)
Bank One Plaza The Nemours Building
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
-and- Attomeys for Farloc Argentina S. A.
PACHULSKI, STANG, ZIEHL, YOUNG, JONES
& WEINTRAUB P.C.
Lauraé-S avis Jones (Bar N0. 2436)
James E. O’Neill (Bar No. 4042)
919 North Market Street, 16"' Floor
P.O. Box 8705
Wilmington, Delaware 19899-8705 (Courier 19801)
Telephone: (302) 652-4100
Facsimile: (302) 652-4400
Attorneys for Debtors and Debtors-in—Possession
IT IS SO ORDERED this day of
, 2005.
l United States District Judge
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