Free Motion for Leave to File - District Court of Delaware - Delaware

Case 1:05-cv-00023-JJF

Document 116

Filed 01/11/2008

Page 1 of 1

UNITED STATES DISTRICT COURT FOR THE DISTRICT OF DELAWARE

DOW CHEMICAL CANADA INC. on its own behalf and as assignee of THE DOW CHEMICAL COMPANY, Plaintiff, v. HRD CORPORATION (d/b/a Marcus Oil & Chemical) Defendant.

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Case No. 05-023 (JJF)

DOW'S MOTION FOR LEAVE TO FILE A SUPPLEMENTAL PAPER IN OPPOSITION TO HRD'S SECOND MOTION TO COMPEL AND FOR SANCTIONS Pursuant to Local Rule 7.1.2., Plaintiffs Dow Chemical Canada, Inc. and The Dow Chemical Company (collectively "Dow"), hereby petition for leave to file a supplemental, 3page paper in the form attached hereto, in further support of its opposition to HRD Corporation's Second Motion to Compel Production of Documents and for Sanctions ("Motion") which is currently pending before this Court. Wherefore, Plaintiffs respectfully request that the Court enter an order in the form attached permitting Dow to file the attached submission in further support of its opposition to HRD's Motion. MORRIS, NICHOLS, ARSHT & TUNNELL LLP

OF COUNSEL: Harry J. Roper Raymond N. Nimrod Aaron A. Barlow JENNER & BLOCK LLP 330 N. Wabash Ave. Chicago, IL 60611 (312) 222-9350 Dated: January 11, 2008

/s/ Kenneth J. Nachbar Kenneth J. Nachbar (#2067) Samuel T. Hirzel (#4415) 1201 N. Market Street Wilmington, DE 19899-1347 (302) 658-9200 Attorneys for Plaintiff The Dow Chemical Company