Free Stipulation to EXTEND Time - District Court of Delaware - Delaware

Case 1:08-cv-00352-SLR

Document 13

Filed 08/25/2008

Page 1 of 2

UNITED STATES DISTRICT COURT DISTRICT OF DELAWARE GLORIA M. HARRISON, Plaintiff, v. RENATA J. HENRY, individually and in her official capacity as Director of the Division of Alcoholism, Drug Abuse and Mental Health of the Delaware Department Health and Social Services, SUSAN WATSON ROBINSON, individually and in her official capacity as Hospital Director of the Delaware Department of Health and Social Services, PHILIP THOMPSON, individually and in his capacity as Unit Director of the Delaware Department of Health and Social Services, DELAWARE DEPARTMENT OF HEALTH & SOCIAL SERVICES and THE DELAWARE PSYCHIATRIC CENTER, and John Does 1-20, Defendants. ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) )

C.A. No. 08-352 (SLR)

JURY TRIAL DEMANDED

STIPULATION TO EXTEND TIME FOR PLAINTIFF'S RESPONSE TO DEFENDANTS' MOTION TO DISMISS PURSUANT TO FED. R. CIV. P. 12(b)(1) and 12(b)(6) It is hereby stipulated and agreed upon by Plaintiff Gloria Harrison (the "Plaintiff"), through her undersigned counsel and Defendants Delaware Department of Health and Social Services, the Delaware Psychiatric Center, Renata Henry, Susan Watson Robinson, and Philip Thompson (collectively the "Defendants"), through their undersigned counsel that Plaintiff's deadline to respond to Defendants' Motion to Dismiss pursuant to FED. R. CIV. P. 12(b)(1) and 12(b)(6), shall be extended until August 29, 2008.

Case 1:08-cv-00352-SLR

Document 13

Filed 08/25/2008

Page 2 of 2

ARCHER & GREINER, P.C. /s/ "J" Jackson Shrum "J" Jackson Shrum (# 4757) 300 Delaware Avenue, Suite 1370 Wilmington, DE 19801 (302) 777-4350 (telephone) (302) 777-4352 (fax) [email protected] Counsel to Plaintiff

WOLFBLOCK LLP /s/ Kathleen M. Jennings Kathleen M. Jennings (# 913) Joseph C. Schoell (# 3133) 1100 N. Market Street, Suite 1001 Wilmington, DE 19801 (302) 777-6926 (telephone) Counsel to Defendants Dated: August 25, 2008

Dated: August 25, 2008

SO ORDERED AND APPROVED.

THE HONORABLE SUE L. ROBINSON

2

Case 1:08-cv-00352-SLR

Document 13-2

Filed 08/25/2008

Page 1 of 1

UNITED STATES DISTRICT COURT DISTRICT OF DELAWARE GLORIA M. HARRISON, Plaintiff, v. RENATA J. HENRY, individually and in her official capacity as Director of the Division of Alcoholism, Drug Abuse and Mental Health of the Delaware Department Health and Social Services, SUSAN WATSON ROBINSON, individually and in her official capacity as Hospital Director of the Delaware Department of Health and Social Services, PHILIP THOMPSON, individually and in his capacity as Unit Director of the Delaware Department of Health and Social Services, DELAWARE DEPARTMENT OF HEALTH & SOCIAL SERVICES and THE DELAWARE PSYCHIATRIC CENTER, and John Does 1-20, Defendants. ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) )

C.A. No. 08-352 (SLR)

JURY TRIAL DEMANDED

CERTIFICATE OF SERVICE I hereby certify that I caused true and correct copies of the Stipulation to Extend Time for Plaintiff's Response to Defendants' Motion to Dismiss Pursuant to Fed. R. Civ. P. 12(b)(1) and 12(b)(6) to be served via regular mail and Lexis/Nexis File and Serve upon the following: Kathleen M. Jennings (# 913) Joseph C. Schoell (# 3133) WOLFBLOCK LLP 1100 N. Market Street, Suite 1001 Wilmington, DE 19801

Dated: August 25, 2008
3507692v1

/s/ "J" Jackson Shrum "J" Jackson Shrum