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

Case 1:05-cv-00063-SLR

Document 6-4

Filed 05/20/2005

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IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF DELAWARE AMERICAN EMPLOYERS' INSURANCE COMPANY, as subrogee of College Book Stores of America One Beacon Street Boston, MA 02108 Plaintiff, v. T.A. RIETDORF & SONS, INC. P.O. Box 1528 Wilmington, DE 19899 Defendant. : : : : : : : : : : : : : : :

C.A. No. 05-63-SLR

JOINT MOTION AND STIPULATION FOR EXTENSION OF TIME IN WHICH TO RESPOND TO DEFENDANT'S MOTION TO DISMISS Plaintiff, American Employers' Insurance Company, as subrogee of College Book Stores of America, hereby moves this Honorable Court for an Extension of Time in Which to Respond to Defendant's Motion to Dismiss and in support of their Motion avers as follows: 1. On or about May 12, 2005, Plaintiff was served with a copy of Defendant's

Motion for Summary Judgment in this case. 2. Pursuant to the Federal Rules of Civil Procedure and the Local Rules of the

United States District Court for the District of Delaware, Plaintiff's Response to the Motion to Dismiss is due on or before May 23, 2005. 3. Counsel for Defendant has consented to providing Plaintiff with an extension of

time to respond to its Motion until May 31, 2005. 4. Plaintiff respectfully requests that this Court extend the time for the filing of

Plaintiff's Response to Defendant's Motion to Dismiss from May 23, 2005 up to and including May 31, 2005.

Case 1:05-cv-00063-SLR

Document 6-4

Filed 05/20/2005

Page 2 of 2