KOP:236231v1 4523-01

IN THE UNITED STATES DISTRICT COURT

FOR THE EASTERN DISTRICT OF PENNSYLVANIA

_____________________________________________________________________________

JOYCE R. MONGER : CIVIL ACTION – LAW

:

v. : NO.: 02-CV-2757

:

SALOMON J. BERENHOLZ : JURY TRIAL DEMANDED

_____________________________________________________________________________

STIPULATED MOTION FOR EXTENSION OF ALL DISCOVERY DEADLINES

Plaintiff and Defendant, by and through their undersigned counsel, hereby move this Court

for an extension of all discovery deadlines, including the December 2, 2002 discovery deadline,

and the January 2, 2003 summary judgment deadline in the above captioned case. In support of

their motion, the parties state as follows:

1. The current discovery deadline is December 2, 2002.

2. The current deadline for filing motions for summary judgment or partial summary

judgment is January 2, 2003.

3. The parties have engaged in written discovery to date.

4. On or about November 22, 2002, Defendant served answers to interrogatories and

document requests.

5. Due to the information provided in these discovery responses, Defendant anticipates that

he will need to take one or more depositions.

6. Additionally, Plaintiff anticipates that she will need to take one or more depositions as

well.

7. The parties are currently involved in scheduling mutually agreeable dates for depositions.

8. Due to the depositions currently being scheduled and the possibility of follow up

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KOP:236231v1 4523-01

discovery, it is anticipated that discovery will not be completed by the current discovery

deadline of December 2, 2002.

9. Additionally, due to the contemplated discovery that the parties will engage in, an

extension of time is necessary for summary judgment or partial summary judgment

motions.

10. The parties have conferred and agree that a limited extension of all discovery deadlines is

necessary in order to allow the completion of discovery in this case.

11. This is the first requests by either party for an extension of the discovery deadlines in this

case.

12. The undersigned counsel understand that this matter is presently scheduled for trial on

March 17, 2003, pursuant to the Scheduling Order entered on August 19, 2002.

13. Should the Court, in its discretion, determine that revising the deadline for the filing of

motions for summary judgment or partial summary judgment will leave the Court with

insufficient time to render a decision on any such motions prior to trial, the parties

respectfully request that trial in this action be rescheduled for April 17, 2003, thereby

allowing an additional thirty (30) days for a review of dispositive motions prior to trial.

WHEREFORE, the parties respectfully request that their stipulated motion be granted and

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that an Order be entered, in the form attached hereto, extending all discovery deadlines by sixty

(60) days and setting the discovery deadline in this case as February 3, 2003 and the deadline for

filing motions for summary judgment or partial summary judgment as February 3, 2003.

Respectfully submitted,

Dated: November 27, 2002 _________________________

Gary A. DeVito

Joseph W. Denneler

Zarwin Baum DeVito Kaplan O’Donnell &

Schaer, PC

1515 Market Street, Suite 1200

Philadelphia, PA 19102

(215) 569-2800

(215) 569-1606 (fax)

Counsel for Plaintiff

Dated: November 27, 2002 _________________________

Michael G. Trachtman

Kevin K. Carton, Jr.

Powell Trachtman Logan Carrle Bowman &

Lombardo P.C.

475 Allendale Road, Ste. 200

King of Prussia, PA 19406

(610) 354-9700

(610) 354-9760 (fax)

Counsel for Defendant 

Case 2:02-cv-02757-TJS Document 9 Filed 11/29/2002 Page 3 of 5
KOP:236231v1 4523-01

IN THE UNITED STATES DISTRICT COURT

FOR THE EASTERN DISTRICT OF PENNSYLVANIA

_____________________________________________________________________________

JOYCE R. MONGER : CIVIL ACTION – LAW

:

v. : NO.: 02-CV-2757

:

SALOMON J. BERENHOLZ : JURY TRIAL DEMANDED

_____________________________________________________________________________

ORDER

AND NOW, this ____________day of _________________, 2002, upon consideration of

the parties Stipulated Motion for Extension of Discovery, it is hereby ORDERED and DECREED

that the motion is GRANTED, and that all discovery deadlines are extended by sixty (60) days

and the discovery deadline in this case is extended until February 3, 2002. 

It is FURTHER ORDERED that motions for summary judgment or partial summary

judgment shall be filed on or before February 3, 2002.

___________________________________

J.

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KOP:236231v1 4523-01

Certificate of Service

I, Kevin K. Carton, Jr., certify that on this day a true and correct copy of the foregoing

Stipulated Motion for Extension of All Discovery Deadlines was served upon the following

counsel of record via first class mail, postage prepaid, addressed as follows:

Gary A. DeVito, Esquire

Zarwin Baum DeVito Kaplan O’Donnell & Schaer, PC

1515 Market Street, Suite 1200

Philadelphia, PA 19102

(Attorney for Plaintiff)

Dated: November 27, 2002 ___________________________

Kevin K. Carton, Jr.

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