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

Case 1 :05-cv-00127-GIVIS Document 8 Filed 05/18/2005 Page 1 of 2
IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF DELAWARE
MARIANNE DUFFY, by her parents and )
legal guardians, Sean and Elise Duffy, )
)
Plaintiff, )
)
v. ) No 05-CV-127-GMS
)
VINCENT MECONI, Secretary, Delaware )
Department of Health & Social Services, in )
his official capacity, )
)
MARIANNE SMITH, Director, Division of )
Developmental Disabilities Services, )
in her official capacity, and )
)
ELAIN E ARCHANGELO, Director, Division )
of Social Services, in her official capacity, )
)
Defendants. )
SECOND STIPULATION FOR AN EXTENSION
OF DEFENDANTS’ TIME TO RESPOND TO THE COMPLAINT
AND FOR LIMITED INITIAL DISCOVERY A
All parties to this action, by and through their respective attorneys, hereby stipulate and
agree as follows:
l. The time within which defendants may serve and file their response to plaintiffs
Complaint is extended to May 25, 2005. Absent an affirmative showing of good cause to the
Court, no further extension of time to respond to the Complaint shall be permitted.
2. If defendants file a Motion to Dismiss, plaintiff may file and serve her answering
brief (and any supporting materials) no later than July 8, 2005. Defendants may then file and
serve a reply brief (and any supporting materials) no later than July 18, 2005. Plaintiff may then

Case 1:05-cv—00127-G|\/IS Document 8 Filed 05/18/2005 Page 2 of 2
file and serve a sur-reply brief (and any supporting materials) no later than July 29, 2005.
Defendants’ reply brief and plaintiff s sur-reply brief shall each not exceed ten (10) pages.
3. The parties may conduct limited written discovery in advance of the Rule 26(f)
conference of the parties.
IT IS SO STIPULATED.
F//7kr E 3·l‘\'2|¤$"`
Daniel G. Atkins Richard M. Donaldson
(DE Bar I.D. No. 2970) (DE Bar I.D. No. 4367)
MaryBeth Musumeci Montgomery, McCracken,
(DE Bar I.D. No. 4128) Walker & Rhoads, LLP
Community Legal Aid Society, Inc. 300 Delaware Avenue, Suite 750
Disabilities Law Program Wilmington, DE 19801
Community Service Building (302) 504-7800
100 West 10th Street, Suite 801
Wilmington, DE 19801 Counsel for Defendants
(302) 575-0660
Counsel for Plaintiff
APPROVED BY THE COURT:
Gregory M. Sleet, U.S.D.J.
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