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

Case 1:06-cv-00417-GMS

Document 55

Filed 08/07/2007

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IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF DELAWARE COLGATE-PALMOLIVE COMPANY, PLAINTIFF, V. RANIR, L.L.C., DEFENDANT. ) ) ) ) ) ) ) )

Civil Action No. 06-417-GMS

STIPULATION AND PROPOSED ORDER FOR EXTENSION OF TIME TO SERVE OPENING EXPERT REPORTS WHEREAS, the deadline for service of opening expert reports in the above matter is August 7, 2007 (D.I. 51); WHEREAS, the parties are engaged in settlement discussions and respectfully request a three-day extension of that deadline; and WHEREAS, the parties are mindful of the Court's usual practice of not altering the case schedule in order to facilitate settlement talks, but are hopeful that the Court will make an exception in this instance because: (i) the proposed extension is just three days; (ii) no other date in the case schedule will be impacted; and (iii) the parties are concerned that the service of adversarial expert reports at this juncture would be counterproductive to the settlement process; now therefore, IT IS HEREBY STIPULATED AND AGREED, subject to the approval and order of the Court, that the deadline for service of opening expert reports is extended through and including August 10, 2007.

Case 1:06-cv-00417-GMS

Document 55

Filed 08/07/2007

Page 2 of 2

/s/ Francis DiGiovanni________________ Francis DiGiovanni (#3189) Connolly Bove Lodge & Hutz LLP The Nemours Building 1007 North Orange Street P.O. Box 2207 Wilmington, DE 19899 Telephone: (302) 658-9141 [email protected] Attorneys for Colgate-Palmolive Company

/s/ Steven J. Balick_____________________ Steven J. Balick (#2114) Ashby & Geddes 500 Delaware Avenue, 8th Floor P.O. Box 1150 Wilmington, Delaware 19801 Telephone: (302) 504-3700 [email protected] Attorneys for Ranir, L.L.C.

SO ORDERED this ____ of August, 2007.

____________________________________ Chief United States District Judge

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