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

Case 1:04-cv—01262-G|\/IS Document 16 Filed 05/12/2005 Page 1 of 2
IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF DELAWARE
In re: ) Chapter ll
)
INTEGRATED HEALTH SERVICES, ) Case No. 00-00389 (MFW)
INC., etal., )
) (Jointly Administered)
Debtors. )
)
INDEMINITY INSURANCE COMPANY )
OF NORTH AMERICA, )
)
Plaintiff, )
‘ )
v. ) C.A. No. 04-1262 (GMS)
)
INTEGRATED HEALTH SERVICES, )
INC. and ABE BRIARWOOD CORP., )
)
Defendants. )
DEFENDANT ABE BRIARWOOD CORP.’S MOTION
FOR EXTENSION OF TIME TO FILE A RESPONSE
Defendant Abe Briarwood Corp., by and through its undersigned counsel, hereby moves
for an extension of time to file a response to Motion to Amend Complaint, and in support thereof
states as follows:
1. There are two (2) separate defendants in this adversary proceeding. Upon
information and belief, Defendant Integrated Health Services, Inc. requested and received a short
extension of time to respond to the Motion to Amend Complaint.
2. Defendant Abe Briarwood Corp. rnade a similar request which was denied by
Plaintiff. Given that Briarwood continues to be in the process of reviewing the proposed
nineteen (19) page amended complaint to determine whether the additional relief requested
affects Bria1wood’s rights, Briarwood respectfully requests an extension of its time to respond to
May 19, 2005.
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Case 1 :04-cv—01262-GIVIS Document 16 Filed 05/12/2005 Page 2 of 2
WHEREFORE, Defendant moves for an extension of time, up to and including May 19,
2005 to tile a response to the Motion and for such other and further relief as the Court deems just
and proper.
Dated: May 12, 2005
Wilmington, Delaware
JASPAN SCHLESINGER HOFFMAN LLP
By: /s/ Frederick B. Rosner
Frederick B. Rosner (No. 3995)
913 N. Market Street, 12th Floor
Wilmington, Delaware 19801
Telephone: (302) 351-8000
Facsimile: (302) 351-8010
» Counsel to Abe Briarwood Corp.
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