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

Case 1 :04-cv-01462-KAJ Document 40 Filed 08/19/2005 Page 1 of 3
IN THE UNITED STATES DISTRICT COURT
FOR THE DISRTRICT OF DELAWARE
April Baylis, :
: C.A. No.:04—1462 KAJ
Plaintiff, :
v. Trial by Jury Demanded
Red Lion Group Inc., a corporation :
of the State of Pennsylvania, :
Defendant.
MOTION FOR EXTENSION OF TIME
l. Defendant, Red Lion Group, Inc. filed a Motion for Summary Judgment
on August 5, 2005.
2. Plaintiffs answer to such motion was originally due on August i9,
2005.
3. Counsel for Plaintiff has been in the hospital caring for his daughter for
the past week.
4. Doctors have not been able to diagnose her and there is currently no
discharge plan.
5. Because he has been with his daughter, Counsel for Plaintiff has been
unable to secure the needed affidavits and due to necessary research in
order to properly prepare for Plaintiff’ s answer to Defendant’s Motion
for Summary Judgment.
6. Counsel for Plaintiff called Counsel for Defendant requesting an
extension to answer his Motion for Summary Judgment.
7. Counsel for Defendant is agreeable to an extension to answer his
Motion for Summary Judgment until August 26, 2005.

Case 1:04-cv-01462-KAJ Document 40 Filed 08/19/2005 Page 2 of 3
S. Due to anticipated hospital transfers in the upcoming days, Counsel for
Plaintiff requests an extension to August 29, 2005 to answer
Detendaufs Motion for Summary Judgment.
Bayard garin
The Law Offices of Bayard Marin
521 West Street
Wilmington, DE 19801
302-65 8-4200
Attorney for Plaintiff
Dated: August 19, 2005

Case 1:04-cv-01462-KAJ Document 40 Filed 08/19/2005 Page 3 of 3
[N THE UNITED STATES DISTRICT COURT
FOR THE DISRTRICT OF DELAWARE
April Baylis, :
: C.A. No.:04—1462 KAJ
Plaintiff, :
v. Trial by Jury Dema I ded
Red Lion Group Inc., a corporation
of the State of Pennsylvania, :
Defendant.
CERTIFICATE OF SERVICE
I, Bayard Marin, Esquire, hereby certiiy that on this 19th day of August 2005, that
I caused two true and correct copies of a Motion for Extension of Time to be served by
electronic filing upon the following counsel of record:
Norman H. Brooks, Jr., Esquire
Marks, O'Neill O‘Brien & Courtney, P.C.
913 North Market Street, Suite 800
Wilmington, DE 19801 /
Ba cl arin
The Otiices of Bayarcl Marin
521 West Street
Wilmington, DE 19801
302-658-4200
Attorney for Plaintiff
Dated: August I9, 2005