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

Case 1:05-cv-00746-MPT

Document 65

Filed 06/16/2008

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IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF DELAWARE ) ) Plaintiff, ) ) v. ) ) THE DELAWARE RIVER AND BAY ) AUTHORITY, JAMES JOHNSON, ) Individually, JAMES WALLS, Individually, ) TRUDY SPENCE-PARKER, Individually, ) and CONSUELLA PETTY-JUDKINS, ) Individually. ) ) Defendants. ) RONALD S. RILEY,

C.A. No. 05-746 (MPT) (Consolidated)

DEFENDANTS' UNOPPOSED MOTION TO EXTEND DEADLINE TO FILE REPLY BRIEF Defendants, Delaware River and Bay Authority, James Johnson, Trudy SpenceParker, and Consuella Petty-Judkins, (hereinafter "Defendants") seek an extension of time to file their Reply Brief in Support of their Motion for Summary Judgment, for the following reasons: 1. On May 15, 2008, Defendants, filed their Motion for Summary Judgment

and Opening Brief in Support thereof, pursuant to the Court's June 28, 2007 Scheduling Order. 2. 2, 2008. 3. On May 29, 2008, Plaintiff filed a Motion to Extend Deadline to file his Pursuant to the Local Rules, Plaintiff's Answering Brief was due on June

response to Defendant's case dispositive motion, requesting a one-week extension, to June 9, 2008, to file his brief. 4. On June 9, 2008, Plaintiff filed his Answering Brief in Opposition to

Defendants' Motion for Summary Judgment.

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Case 1:05-cv-00746-MPT

Document 65

Filed 06/16/2008

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5. 2008. 6.

The docket now reflects that Defendants' Reply Brief is due on June 19,

Defendants' response has now been further complicated by the fact that

one of the individual defendants, Trudy Spence-Parker, resigned from the Delaware River and Bay Authority and retained separate counsel. 7. Defendants therefore respectfully request a one-week extension of time to

file their Reply Brief in Support of their Motion for Summary Judgment, making their Reply Brief due on June 26, 2008. 8. Per Plaintiff's Motion to Extend Deadline, Plaintiff does not oppose

Defendants' request for a one-week extension of time. WHEREFORE, Defendants respectfully requests a one-week extension until June 26, 2008, to file their Reply Brief in Support of their Motion for Summary Judgment. YOUNG CONAWAY STARGATT & TAYLOR, LLP /s/ Adria B. Martinelli__________________________ William W. Bowser, Esquire (Bar I.D. 2239) Adria B. Martinelli, Esquire (Bar I.D. 4056) The Brandywine Building, 17th Floor 1000 West Street P.O. Box 391 Wilmington, Delaware 19899-0391 Telephone: (302) 571-6601, 6613 Facsimile: (302) 576-3282, 3314 Email: [email protected] [email protected] Attorneys for Defendants DATED: June 16, 2008

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