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

Case 1:07-cv-00387-JJF Document 24 Filed 05/27/2008 Page 1 of 3
IN THE UNTIED STATES DISTRICT COURT
FOR THE DISTRICT OF DELAWARE
DELSIE E. BROOKENS, )
)
PLAINTIFF, )
) C.A. No. 07-387(JJF)
v. )
)
GENERAL MOTORS CORPORATION, a Delaware )
Corporation, GENERAL MOTORS CORPORATION, )
Plan Administrator, and GM HOURLY-RATE )
EMPLOYEES PENSION PLAN, an employee pension )
beneiit plan, )
DEFENDANTS. )
MOTION TO REQUEST EXTENTION OF TIME FOR
PLAINTIF F TO FILE MOTION FOR SUMMARY JUDGMENT
COMES NOW, Plaintiff Delsie E. Brookens, through counsel, and
Moves this Court for an Extension of Time in which Plaintiff is to file Motion for
Summary Judgment in the above action. In support of this Request, Plaintiff states
that her Counsel has been unable to contact his client as to needs of her
information in support of said motion, and, in addition, has had ’n1rther time
constraints due to other court requirements, thereby restricting his availability to
formulate an adequate analysis of the Afiirmative Defenses of Defendants’
Answer, thereby necessitating this Motion. Counsel had discussed same and
previously agreed as to Plaintiff submitting an extension of time request to the
Court.
WHEREFORE, Plaintiff therefore requests an extension of time sufficient in
which to file a Motion for Summary Judgment.
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Case 1:07-cv-00387-JJF Document 24 Filed 05/27/2008 Page 2 of 3
/s/ JOHN M. STULL
John M. Stull, (Bar #568)
Attorney for Plaintiff
3 Mill Road, Ste #306A
P. O. Box 1947
Wilmington, DE 19899
[email protected]
Dated: May 27, 2008
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Case 1:07-cv-00387-JJF Document 24 Filed 05/27/2008 Page 3 of 3
CERTIFICATE OF SERVICE
I, John M. Stull, counsel for plaintiff herein, do certify that I did on or
before May 27, submit the within request to the Court for Extension of Time to file
a Motion for Summary Judgment via e-mail, and also forwarded a copy of this
Briefing in support thereof as a response to Defendants’ Motion for Summary
Judgment, and did send a copy of same to counsel for Defendants via U. S. Mail,
postage prepaid, with additional copies to the Court, and to Counsel at Eckert
Seamans Cherin & Mellot, LLC, 300 Delaware Avenue, Ste 1210, Wilmington,
DE 19801, via e-mail to Margaret F. England, [email protected].
/s/ JOHN M. STULL
John M. Stull, (Bar #568)
Attorney for Plaintiff
3 Mill Road, Ste #306A
P. O. Box 1947
Wilmington, DE 19899
[email protected]
Dated: May 27, 2008
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