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

ase 3:00—cv-00894—t1_CH Document 26 Filed 10/31 /2003 Page 1 of 3
UNITED STATES DISTRICT COURT
DISTRICT OF CONNECTICUT
BAY VIEW COMMERCIAL :
LEASING, INC. : Civil Action No.
: 3:CV0894(J CH)
v. :
PATRICK GLENN, MICHAEL
GLENN, and RONALD R. SCHUELER : October 30, 2003
MOTION FOR ENLARGEMENT OF TIME UPON CONSENT
Pursuant to Rule} 9(a)i ofthe Local Rules of Civil Procedure, undersigned counsel of record
for Plaintiff Bay View Commercial Leasing, Inc. ("Bay View") in the above-captioned action
hereby moves for an order of this Court enlarging the time until December 19, 2003 to respond to
Defendant Ronald Schueler’s Motion to Vacate Judgment dated August 12, 2003 (the "Schueler
Motion"). In support of this motion, the undersigned represents as follows:
1. Bay View has transferred the Judgment to a third party (the "New Owner")-
2. On October 3, 2003, this Court granted Bay View's motion for enlargement of time,
extending through October 31, 2003 the date by which a response to the Schueier Motion had to
be filed with the Court.
p 3. The parties have been discussing a resolution of the Schueler Motion.
4. In iight ofthe discussions, the New Owner wishes to have additional time to respond
to the Schueier Motion.
5. Undersigned counsel has contacted Iliinois counsel for Defendant Ronald Schueler,
Scott Kapp, Esq. of Amstein & Lehr, who consents to the enlargement of time sought in this
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ase 3:OO—cv-008945JCH Document 26 Filed 10/31/2003 Page 2 ot 3
motion.
6. Pursuant to this Court’s Order to Show Cause (the "Order") dated October 16, 2003,
Mr. Schueler has until November 5, 2003 to respond to the Order or tile an objection to the
Motion to Withdraw Appearance filed by Attorney David M. Bizar of Day Berry & Howard
LLP. The Court has also set a date of December 1, 2003 for Mr. Schueier to tile a pro se
appearance or another attorney to tile an appearance.
7. This is the third motion requesting an extension of time addressed to the Schueler
Motion.
WHEREFORE, it is respectfully requested that this Court enter an order enlarging the
time by which a response must be liked to the Schueier Motion to and including December 19,
2003.
PLAIN&11I~§§`F
BAY V EW COMMERCIAL LEASING, INC.
i E7
By _ `. _ _._- =_ L
Dominic Fuldo IH (ct06494)
Reid and Riege, P.C.
One Financial Plaza
Hartford, CT 06103
(860) 278-1150
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ase 3:00-cv-00394-JCH Document 26 Filed 10/31/2003 Page 3 of 3
CERTIFICATION OF SERVICE
This is to certify that a copy ofthe foregoing was mailed via first class mail, postage
prepaid on this 30m day of October, 2003:
David M. Bizar, Esq.
Day Berry & Howard LLP
CityPIace I
Hartford, CT 06i03
Scott Kapp, Esq.
Amstein & Lehr M,
120 S. Riverside Plaza { it
Suite 1200 = E.
Chicago, H. 60606 7
QM tv are
Dominic atc HI _
1955}.000/344040.1
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