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

Case 1 :07-cv-00406-SLR Document 6 Filed 07/12/2007 Page 1 of 2
IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF DELAWARE

PETER D. I RNESS ELECTRIC CO., INC., )
Plaintiff] g
v. g C. A. N0. 07-406 SLR
TCS INT EI ATIONAL, INC., g
Defendant. g
STIPULATION TO EXTEND TIME
FOR FILING A RESPONSE TO COMPLAINT
COI NOW the Plaintiff, Peter D. Furness, Electric Co., Inc. ("Furness") and
Defendant, ‘ TS International, Inc. ("TCS"), and hereby stipulate to extend the time in which the
Defendant, ‘S, must tile a response to the Complaint in this matter. The parties respectfully
request that js Court extend the time in which TCS must file a response to the Complaint for
twenty (20) ys. In support of and as grounds for this stipulation, the parties state as follows:
1. On June 22, 2007, Furness filed the Complaint in this Court and served the
Summons a Complaint on the Registered Agent of TCS with the Secretary of State’s Office in
Dover, Dc]: ire. Furness sent via registered mail a copy ofthe Complaint, Summons and
Secretary o: tate’s Return of Service to counsel for TCS, Massachusetts Attorney Walter M.
Foster on Jl - 26, 2007.
2. Mr. Foster was unavailable during the week of July 2"d through July 6°h, 2007, and
after receivi . notice of service of the Complaint on July 9th, retained local counsel in Delaware
on July I2, 07 to represent TCS in this matter.

Case 1:07-cv-00406-SLR Document 6 Filed 07/12/2007 Page 2 of 2
3. TCS’s response is presently due to be filed in this Court by July 16, 2007. An
additional s ieen (16) days, or until August 1, 2007, would not prejudice either party, and the
Plaintiff’s c nsel of record has assented to this brief extension of time. In addition, the Court
has not sch· 11ed any hearing or other event in this matter.
CONCLUSION
Sint he granting of this brief extension for TCS to file a response to the Complaint
would not c erwise prejudice any party, and based on all of the foregoing reasons, Furness and
TCS agree. 1 respectfully request that this Court approve this Stipulation to extend time in
which the I `endant, TCS, must tile a response to the Complaint, up to and including August 1, _
2007.
Respectfull ubmitted,
BUCI-lAN.¢ INGERSOLL & ROONEY, P.C. COHEN SEGLIAS PALLAS GREENHALL
& FURMAN P.C.
fsf Jennifer . Becnel-Guzzo /s/ Robert K. Beste, Jr.
William E. inning, Esquire (#697) Robert K. Beste, Jr., Esquire (#154)
Jennifer M. scncl-Guzzo, Esquire (#4492) Nemours Building, Suite 1130
The Brandy ne Building 1007 North Orange Street
1000 West cet, Suite 1410 Wilmington, DE 19801
Wilmingtor )E 19801 (302) 425-5089
(302) 552-4 0 (302) 425-5097 (facsimile)
(302) 552-4 5 (facsimile) [email protected]
wi1liam.ma [email protected]
jennifenbec [email protected] Arrorneysfor PZczinty§"Perer D. F umass
Electric Co., Inc.
Of Counsel
Walter M. l iter, Esquire (BBO #552917)
SHEEHAN IINNEY BASS + GREEN, P.A.
One Bostor lace, 38th Floor
Boston, MF 2108
(617) 897-5 6
Attorneys]? Defendant TCS Inrernatirmm', Inc.
July 12, 20{

Case 1:07-cv—00406-SLR Document 6-2 Filed 07/12/2007 Page 1 of 1
IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF DELAWARE

PETER D. I RNESS ELECTRIC CO., INC., )
P1aintif1Q g
v. 3 C. A. N0. 07-406 SLR
TCS INTEF ATIONAL, INC., I
Defendant. g
_ )
PROPOSED] ORDER EXTENDING TIME FOR DEFENDANT
I FILE RESPONSIVE PLEADING TO PLAINTIFF’S COMPLAINT
Upo onsideration of the parties’ Stipulation To Extend Time For Filing A Response To
Complaint:
IT It IEREBY ORDERED THAT:
The IC in which the Defendant, TCS International, Inc., must tile a responsive pleading
to the Pl 1tiff`s Complaint, is hereby extended through and including August 1, 2007.
SO ORDERED,
Dated: ; , 2007
The Honorable Sue L. Robinson
#i00a00s-vi