Free Proposed Order - District Court of Delaware - Delaware

f Case 1 :04-cv-00407-GI\/IS Document 19 Filed O2/O2/2006 Page 1 of 2
IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF DELAWARE
In re:
° BROADBAND OFFICE, INC. C.A. No. 04-407 (GMS)
Debtor.
BROADBAND OFFICE, INC., Bankruptcy C.A. No. 01-1720 (GMS)
Chapter ll
I Plaintiff, g
TECHNOLOGY CREDIT
CORPORATION d/b/a EXTREME
NETWORKS CREDIT CORPORATION,
and EXTREME NETWORKS, INC.,
and
KEY EQUIPMENT FINANCE, INC. ffk/a
KEY CORPORATE CAPITAL, INC. f7k/a
LEASTEC CORPORATION,
Defendants.
STIPULATED ORDER EXTENDING BRIEFING SCHEDULE
Whereas Key Equiprnent filed its Motion to Dismiss and Brief in Support thereof
on January 31, 2006; and,
Whereas, Plaintiffs Reply Brief would be due on February 14, 2006; and,
Whereas, the Parties have agreed to stipulate to the following scheduling order.
Plaintiff Broadband Office, Inc. and Defendants Key Equipment Finance, Inc.,
f/k/a Key Corporate Capital, Inc. f/k/a Least§ Corporation, ("Key Equipment") by and
900200.0000l/40159258v.l

Case 1:04-cv-00407-G|\/IS Document 19 Filed O2/O2/2006 Page 2 of 2
through their respective counsel, hereby stipulate and agree to the following briefing
schedule with regard to Defendant Key Equipment’s Motion to Dismiss:
1. Plaintiff shall have through March 2, 2006 to file its answering brief.
2. Defendant Key Equipment shall have through March 16, 2006 to tile its reply
brief
Plaintiff and Defendant request such additional time in light of the complex
issued raised in Defendant’s motion, including but not limited to statute of limitations and
exceptions thereto, including relation back under Rule 15(c) and novel areas of law such
as identity of the entities, mistake and imputed notice. Counsel for Plaintiff also requests
such additional time due to matters pending in this and other courts which require an
abundance of counsel’s time and resources at this time.
WERB & SULLIVAg7 BLA P
Brian A. S livan (#2098) ev n L. Caponi (DSBA No. 3484)
Amy D. Brown (#407Q 1201 N. Market Street
300 Delaware Ave., 13 Fl. Suite 800
P.O. Box 25046 Wilmington, DE 19801
Wilmington, DE 19899 (302) 425-6400
(302) 652-1100
(3 02) 652-1111 Attomeys for Defendants
Attorneys for Plaintiff Key Equipment Finance, Inc.,
f/k/a Key Corporate Capital, Inc.
f/k/a Leastec Corporation
Dated: ,2///0Q
Dated:
SO ORDERED this day of February, 2006.
The Honorable Gregory M. Sleet
United States District Court Judge
900200.00001/40159258v.t

Case 1:04-cv-00407-GMS

Document 19

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Case 1:04-cv-00407-GMS

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