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

Case 1:07-cv-00023-SLR

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Filed 02/26/2008

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IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF DELAWARE

) ) Plaintiff, ) ) v. ) ) WILMINGTON POLICE OFFICER RINEHART, ) WILMINGTON POLICE OFFICER DRYSDALE, ) ) Defendants. )

ROBERT D. BROWN,

C.A. No. 07-23 (SLR) JURY OF 12 DEMANDED

DEFENDANTS' MOTION TO EXTEND CASE DISPOSITIVE MOTIONS DEADLINE Defendants, by and through counsel, hereby move this Honorable Court to extend the case dispositive motions deadline by one week. In support of their Motion, Defendants offer the following: 1. Currently, the deadline for case dispositive motions is February 28, 2008. No trial

date has been set in this matter. 2. Defendants intend to file a motion for summary judgment. Due to the work schedules

of the Defendant and witness police officers, counsel will not be able to obtain all their affidavits by February 28. The affidavits are necessary to support Defendants' motion for summary judgment. 3. Therefore, Defendants respectfully request that the case dispositive deadline be

extended by one week to March 7, 2008. 4. Defendants do not believe that a one week extension will prejudice Plaintiff given

that no trial date has been set.

Case 1:07-cv-00023-SLR

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5.

Counsel is unable to contact Plaintiff concerning his position with regard to this

Motion because Plaintiff is currently incarcerated. WHEREFORE, Defendants respectfully request that this Honorable Court amend the Rule 16 Scheduling Order to extend the case dispositive deadline to March 7, 2008.

/s/ Rosamaria Tassone Rosamaria Tassone, Esq. (I.D. #3546) First Assistant City Solicitor Louis J. Redding City/County Bldg. 800 N. French St., 9th Flr. Wilmington, DE 19801 Attorney for Defendants

Dated: February 26, 2008

Case 1:07-cv-00023-SLR

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IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF DELAWARE ) ) Plaintiff, ) ) v. ) ) WILMINGTON POLICE OFFICER RINEHART, ) WILMINGTON POLICE OFFICER DRYSDALE, ) ) Defendants. ) ORDER AND NOW, to wit, this _________ day of ____________________2008, the Court having considered Defendants' Motion to Extend the Case Dispositive Motions Deadline, and any opposition thereto, IT IS HEREBY ORDERED that Defendants' Motion to Extend the Case Dispositive Motions Deadline is hereby GRANTED. The new deadline for Case Dispositive Motions is March 7, 2008. ROBERT D. BROWN,

C.A. No. 07-23 (SLR) JURY OF 12 DEMANDED

______________________________ J.

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IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF DELAWARE ROBERT D. BROWN, ) ) Plaintiff, ) ) v. ) ) WILMINGTON POLICE OFFICER RINEHART, ) WILMINGTON POLICE OFFICER DRYSDALE, ) ) Defendants. )

C.A. No. 07-23 (SLR) JURY OF 12 DEMANDED

CERTIFICATE OF SERVICE I, Rosamaria Tassone, Esquire, hereby certify that on this 26th day of February, 2008, I electronically filed Defendants' Motion to Extend the Case Dispositive Deadline with the Clerk of Court using CM/ECF which will send notification of such filing(s) to the following and that these documents are available for viewing and downloading from CM/ECF. A copy of the document was mailed to the following individual: Robert D. Brown Inmate Number 231393 Howard R. Young Correctional Institution P.O. Box 9561 Wilmington, DE 19809

/s/ Rosamaria Tassone Rosamaria Tassone (I.D. #3546) City of Wilmington Law Department Louis L. Redding City/County Building 800 French Street, 9th Floor Wilmington, Delaware 19801-3537 (302) 576-2175