Free Motion for Extension of Time - District Court of Delaware - Delaware

Case 1:04-cv-00366-KAJ

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Filed 09/07/2005

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IN THE FEDERAL DISTRICT COURT FOR THE DISTRICT OF DELAWARE BRIAN NEEFE, individually and : as next of friend to LACEY KNUTSEN,: Plaintiffs, v. GARY LAYFIELD AND DELAWARE STATE POLICE,
Defendants.

JURY TRIAL DEMANDED

: :
:

MOTION FOR EXTENSION OF TIME TO FILE ANSWERING BRIEF IN OPPOSITION TO DEFENDANTS MOTION FOR SUMMARY JUDGMENT NOW COME the Plaintiffs, by and through their attorney, and respectfully represent: 1. That this case involves a civil rights complaint

in which trial is scheduled on November 29, 2005. 2. That defendants filed a Motion for Summary

Judgment with accompanying brief on August 22, 2005. 3. That plaintiffs counsel was on vacation outside

the State of Delaware and did not return to his office until September 6, 2005 and thus had no notification of the motion until that date. 4. That a Mediation Conference is scheduled before

the Honorable Mary Pat Thynge on September 19, 2005. 5. That due to plaintiffs counsel's schedule, which

includes catching up with the work necessary after coming back from a two week vacation plaintiff requests an

extension of time until September 23, 2005 to file the

Case 1:04-cv-00366-KAJ

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Answering Brief in Opposition to the Motion for Summary Judgment. 6. That the position of Michael Tupman, Esquire,

attorney for the defendants with regards to this request is that he does object. WHEREFORE, Plaintiff respectfully prays for an

extension of time until September 23, 2005, to file the Answering Brief in Opposition to defendants Motion for

Summary Judgment.

LAW OFFICE OF EDWARD C. GILL, P.A. _/s/Edward C. Gll______ Edward C. Gill, Esquire Attorney for Plaintiff Bar No. 2112 16 North Bedford Street P.O. Box 824 Georgetown, DE 19947 (302) 854-5400 [email protected]

Dated:

Case 1:04-cv-00366-KAJ

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IN THE FEDERAL DISTRICT COURT FOR THE DISTRICT OF DELAWARE BRIAN NEEFE, individually and : as next of friend to LACEY KNUTSEN,: Plaintiffs, v. GARY LAYFIELD AND DELAWARE STATE POLICE,
Defendants.

JURY TRIAL DEMANDED

: :
:

ORDER After having carefully considered plaintiffs Motion for Extension of Time to File Answering Brief, IT IS HEREBY ORDERED that plaintiff is hereby afforded until September 23, 2005 to file an Answering Brief in Opposition to defendants Motion for Summary Judgment.

___________________________ JUDGE

Case 1:04-cv-00366-KAJ

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CERTIFICATE OF SERVICE I hereby certify that on this 7th day of September, 2005, I caused to be served by electronic filing, and by first-class mail, postage prepaid, two hard copies of the foregoing Motion for Extension of Time to File Answering Brief in Opposition to Defendants Motion for Summary Judgment: W. Michael Tupman, Esquire Department of Justice Kent County 102 West Water Street Dover, Delaware 19904

by United States Mail with postage prepaid. _/s/Edward C. Gill Edward C. Gill