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

Case 1:04-cv-01450-JJF Document 31 Filed 11/14/2005 Page 1 of 2
IN THE UNITED STATES DISTRICT COURT
A FOR THE DISTRICT OF DELAWARE
CASSANDRA JOHNSON, ; C.A. No. 04~l450 (JJF)
. Plaintiff, *
v. I

WAL~MART STORES, INC., 3
. Defendant. *
STIPULATION TO EXTEND BRIEFING SCHEDULE
FOR DISPOSITIVE MOTION AND TO REQUEST
CONTINUANCE OF PRE—TRIAL DATE
COME NOW, the parties, by and through their undersigned
counsel, and hereby stipulate to the extension of the briefing
schedule in this case, and jointly request a continuance, as
follows:
l. Under the current briefing schedule as regulated by the
Local Rules, Plaintiff’s brief in response to Defendant’s Motion
for Summary Judgment would be due on November l5, 2005.
2. Due to professional and personal commitments,
Plaintiff’s counsel will need additional time for completion of
its Answering Brief.
3. Plaintiff’s counsel has confirmed with Defendant’s
counsel that there is no objection to extending the deadline for
the filing of Plaintiff’s Answering Brief to Wednesday, November
30, 2005.
4. Accordingly, Defendant’s counsel requests additional
time for filing of its Reply Brief, that is, until Wednesday,

_ Case 1:04-cv-01450-JJF Document 31 Filed 11/14/2005 Page 2 of 2 .
December 14, 2005.
5. The parties also request that the pre-trial conference,
currently scheduled for January 12, 2006, be continued, to give
the Court opportunity to consider Defendant’s Motion for Summary
Judgment. In addition, this matter is scheduled for mediation
before the Honorable Mary Pat Thynge on January 24, 2006, and the
parties are hopeful that there may be a resolution of this case as
a result of the mediation.
WHEREFORE, the parties jointly request that the deadline for
the filing of Plaintiff’s Answering Brief be extended until
November 30, 2005; that the deadline for the filing of Defendant’s
Reply Brief be extended until December 14, 2005; and that the pre-
trial conference be continued.
SCHMITTINGER & RODRIGUEZ, P.A. BALLARD, SPAHR, ANDREWS &
INGERSOLL, LLP
BY: gs; Noel E. Primos
NOEL E. PRIMDS, ESQUIRE BY: gs/William M. Kelleher
Bar I.D. #3124 WILLIAM M. KELLEHER, ESQ.
414 S. State Street Bar I.D. #3961
P.O. Box 497 919 N. Market Street
Dover, DE 19903 Wilmington, DE 19801
(302) 674-0140 (302) 252-4460
Attorneys for Plaintiff Attorneys for Defendant
DATED:
NEP:pmw
IT IS SO ORDERED this day of , 2005.
THE HONORABLE JOSEPH J. FARNAN JR.