Free Motion for Extension of Time to File Response/Reply - District Court of Delaware - Delaware


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Date: November 15, 2005
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State: Delaware
Category: District Court of Delaware
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Case 1:05-cv-00004-SLR Document 17-3 Filed 11/14/2005 Page 1 of 2
IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF DELAWARE
FLEETBOSTON FINANCIAL : Civil Action No. 05-004 (SLR)
CORPORATION, I MANAGEMENT, INC., ROBERT :
REISNER and WARING IUSTIS, JR., 2
Appellants
v.
Nar, ine., E
Appellee
MOTION FOR AN EXTENSION OF TIME TO FILE
THE BRIEF OF THE APPELLEE, NHT, INC., IN OPPOSITION TO THE APPEAL
Appellant, NHI inc., hereby requests that this Honorable Court grant a two (2) day
extension of time in which to file the Brief of the Appellee in Opposition to the Appeal, and in
support thereof avers as follows:
l. The Brief of the Appellee in Opposition to the Appeal in the above captioned
appeal is due November 14, 2005.
2. Appellee has been working diligently on preparing the Brief in this matter and
addressing the unique legal issues raised by Appellants in this appeal; however, Appellee
requires additional time in order to complete the Brief of the Appellee in Opposition to the
Appeal.
3. Accordingly, Appellee respectfully requests that this Court grant a two (2) day
extension of time in which to file the Brief of the Appellee in Opposition to the Appeai.
4. This is the first extension of time sought hy Appellee in this appeal.
l

Case 1:05-cv-00004-SLR Document 17-3 Filed 11/14/2005 Page 2 of 2
5. On the afternoon of November 14, 2005, Counsel for Appellee attempted to
contact Denise Seastone Kraft, Counsel for Appellants, but was unable to reach her directly——
instead, Counsel for Appellee len a voicemail message for Ms. Kraft inquiring whether
Appellants would agree to a short extension of time in which to file the Brief of the Appellee in
Opposition to Appeal.
6. Appellees respectfully submit that granting the instant Motion for Extension of
Time to File the Brief of the Appellee in Opposition to Appeal and allowing the Appellee an
additional two (2) days to tile its Brief would not cause prejudice to Appellants, and would not
cause inordinate delay to this Honorable Court or delay oral argument in this matter.
WHEREFORE, Appellee, NHL Inc., respectfully requests that this Honorable Court
GRANT the within Motion for an Extension of Time to File the Brief of the Appellee in
Opposition to Appeal.
Respectfully submitted,
/s/Stephen W. Spence
James C. Sargent, Jr. Stephen W. Spence, Esquire (#2033)
PA Attorney l.D. No. 28642 PHILLIFS GOLDMAN & SPENCE, P.A.
Guy A. Donatelli 1200 North Broom Street
PA Attorney LD. No. 44205 Wilmington, DE 19806
Scot R. Withers (302) 655-4200
PA Attorney I.D. No. 84309 (302) 655~42l0 (fax)
LAMB MCERLANE PC Counsel to NHI, Inc.
24 East Market Street
Post Office Box 565
West Chester, PA l938l~—0565
(610) 430~8000
Of Counsel
November 14, 2005
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