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

l Case 1 :05-cv-00028—GI\/IS Document 28 Filed 01/19/2006 Page 1 of 2
IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF DELAWARE
—----··----· -· —----—·-—-----— -· -•———---——-——--—-------- — -—---—- ·— ——--—-•-- X
REX MEDICAL LP,
Plaintiff, C.A. N0. 05-028- GMS
DATASCOPE CORP.,
Defendant.
........................................................................ Q
JOINT STIPULATION
The parties respectfully request, and hereby stipulate to, subject to the Court’s approval,
two modifications to the scheduling order, in order to facilitate the pa1ties’ ongoing efforts to
settle this matter. The parties do not believe the proposed modifications would necessitate a
change in the June 20, 2006 pretrial conference or the July 10, 2006 trial date.
The parties have had multiple meetings with the United States Magistrate as part of
ongoing settlement negotiations to resolve this litigation. These settlement negotiations include r.
potential business transactions between the parties that would resolve the underlying business
disputes. The settlement proposals under discussion involve some complexity in that they
involve the transfer of intellectual property and royalty rights rather than a simple exchange of
cash. Although these settlement efforts have not yet been successful, the parties have made
some progress and both parties are still hopeful that their settlement efforts will be successful.
To allow the settlement negotiations to continue, but also allow the parties to complete "
discovery and prepare to file dispositive motions and have them briefed for the Court in a
Dmi;1967971.1 0629s2.1001

Case 1:05-cv-OOO28—G|\/IS Document 28 Filed O1/19/2006 Page 2 of 2
timely fashion if necessary, the parties respectfully request that the schedule be amended as
follows:
Matter Old Date Proposed New Date
Completion of Fact January 31, 2006 February 28, 2006
Discovery
Cut Off to File Case February 14, 2006 March 14, 2006
Dispositive Motions and
Opening Briefs ·-
Due Date for Answering April 4, 2006
Briefs on Case Dispositive
Motions
Due Date for Reply Briefs April 11, 2006
on Case Dispositive _
Motions
No other dates in the Scheduling Order would be affected.
FOX ROTHSCHILD, LLP YOUNG CONAWAY STARGATT &
TAYLOR, LLP
/s/ Gregory B. Williams /s/ Rolin P. Bissell
Gregory B. Williams(# 4195) Rolin P. Bissell (# 4478)
919 North Market Street, Suite 1300 1000 West Street, 17m Floor
P.O. Box 2323 The Brandywine Building "
Wilmington, DE 19899-2323 Wilmington, DE 19899-0391
302-622-4211 302-571-6560
302-656-8920 (facsimile) 302-576-3474 (facsimile)
gwilliarns@fo>rrothscluld.com [email protected]
Attorneys for Plaintw Rex Medicdl, L. P. Attorneys for Defendant Dcztascope Corp.
Date: January 19, 2006
SO ORDERED this day of , 2005. _
United States District Judge
DB0l:196797l.1 O63982.1001