Free SO ORDERED - District Court of Delaware - Delaware

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IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF DELAWARE
FARLOC ARGENTHWA SA, ) Hon. Joseph H. Rodriguez A
Appellants, l Civil Action No. 04-1549
v. g On Appeal from an Order of the
) United States Bankruptcy Court
FEDERAIJMOGUL GLOBAL INC., et al. ) for the District of Delaware in
) Bankruptcy Case No. OI-10578
Appellees. )
STIPULATION BETWEEN THE DEBTORS AND FARLOC ARGENTINA S. A.
EXTENDING BRIEFING SCHEDULE
Federal-Mogul Global, Inc., et al. (collectively, the "Debtors") and Farloc
Argentina S. A. ("Farloc") hereby stipulate (the "Stipulation") as follows;
WHEREAS, on October 1, 2001, the Debtors commenced their chapter 1 1 cases
by tiling voluntary petitions for relief under title 1 1 ofthe United States Code (as amended, the
i "Bankruptcy Code“);
WHEREAS, on November 17, 2004, the United States Bankruptcy Court for the
District oi`De1uware (the “Bai1irruptcy Court") entered an Order (the "Order") Granting Debtors'
Motion for Order Approving and Authorizing Rejection of Licensing Agreement with Farloc
Argentina S.A. (Bankruptcy Docket No. 6373);
WHEREAS, on November 24, 2004 Farloc tiled its Notice of Appeal in
connection with the Order (Docket No. 6461);
WHEREAS on December 24 , 2004, the Notice of` Appeal was doclceted in the
United States District Court for the District of Delaware (the "District Court");
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WHEREAS, pursuant to a Dishict Court Standing Order dated July 23, 2004, all
appeals from the Banlcruptcy Court to the District Court were referred to mediation and briefing
was suspended for all such appeals;
WHEREAS, on January 6, 2005 Farloc filed its Brief and Appendix;
WHEREAS. on January I4, 2005 the Court entered an Amended Notice of
Docketing indicating that the brieting schedule was no longer deferred and giving the Debtors
until January 27, 2005 to file their answering brief;
WHEREAS, the parties hereto have discussed the briefing schedule and agreed
upon a schedule; and
WHEREAS, the parties hereto had previously agreed to extend the briefing
schedules in the above-captioned appeal to allow the Debtors to file their answering brief no later
than March l4, 2005 and Farloc to file its reply brief no later than March 28, 2005.
_ NOW THEREFORE, in consideration of the foregoing, and subjectto the
approval of the Court, it is hereby stipulated and agreed by and between the Debtors and Farloc
as follows:
l. Notwithstanding F‘ed.R.Bankr.P. 8009, the answering briefs, and the reply
briefs for the above captioned appeal shall be filed according to the following schedule:
a. The Debtors shall file their answering brief on or before April 15,
2005; and
b. Farloc shall Ele its reply brief on or before April 29, 2005.
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Case 1 :04-cv-01549-JHR Document 15-2 Filed O3/15/200gg B ge 3 of 3 H / A
2. Notwithstanding entry ofthe order, and in consideration ofthe extension
of the briefing schedule provided herein, the Debtors agree not to terminate the Licensing
Agreement that was the subject of the Order through and including April J5, 2005.
_ _ not Be expended.
3. The deadlines set forth herein mayutbeiexbenderd nbgrxnutuokagreeurenm
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SIDLEY AUSTIN BROWN & WOOD LLP BUCHANAN INGERSOLL P.C.
James F. Conlan
Larry J. Nyhan t ‘
Kevin T. Lantry *2a-} cir w
Kenneth P. Kansa David E. Wilks (Bar No. 2793)
Bank One Plaza The Nemours Building
10 South Dearborn Street 1007 North Orange Street, Suite 1 l 10
Chicago, Illinois 60603 Wilmington, DE 19801-1236
Telephone: (312) 853-7000 Telephone: (302) 428-5500
P -and- Attomeys for Farloc Argentina S. A.
PAC]-TULSKI, STANG, ZIEHL, YOUNG, JONES
& WEINTRAUB P.C.
Léga Davis Jones (Bar No. 2436)
James E. O’Neil1 (Bar No. 4042)
919 North Market Street, l6"` Floor
P.O. Box 8705
Wilmington, Delaware 19899-8705 (Courier 19801)
Telephone: (302) 652-4lOO
Facsimile: (302) 652-4400
Attorneys for Debtors and Debtors-in-Possession
/ IS SOO ERED this day of
ll ri. . 4.. , 2005.
. . F , . .
Unite i ates istrict Judge ` `
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