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

Case 3:00-cv-00705-CFD

Document 116

Filed 11/02/2004

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UNITED STATES DISTRICT COURT DISTRICT OF CONNECTICUT

IN RE: PE CORPORATION SECURITIES LITIGATION

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Master File No. 3:00CV704(CFD) November 2, 2004

UNITED STATES' MOTION FOR EXTENSION OF TIME The United States, a non-party to this litigation, hereby requests a one week extension of time to file a response to the Plaintiff's Motion to Compel the deposition testimony of Dr. Francis Collins in the above-referenced matter. The Plaintiff's Motion to Compel was filed with this Court on October 12, 2004 and a response was due on November 2, 2004. The undersigned counsel only recently received a complete copy of all of the exhibits attached to the Motion to Compel. A proper response requires additional time to review the several deposition transcripts which are referenced. This is the Government's first motion for extension of time with regard to the Motion to Compel. Pursuant to Rule 7(b) of the Local Civil Rules for the District of Connecticut, the undersigned contacted Plaintiff's counsel, Carlos Ramirez, and the Defendant's counsel, William Regan, who had no objection to the one week extension and also agreed that the Plaintiffs reply to both the Defendant's Response and Partial Opposition and the United States' Response should be filed on or before November 19, 2004.

Case 3:00-cv-00705-CFD

Document 116

Filed 11/02/2004

Page 2 of 3

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The Government will file its response on or before November 9, 2004, Respectfully submitted, KEVIN J. O'CONNOR UNITED STATES ATTORNEY

JOHN B. HUGHES CHIEF, CIVIL DIVISION FEDERAL BAR #ct05289 U.S. ATTORNEY'S OFFICE P.O. BOX 1824 NEW HAVEN, CT 06510 (203) 821-3700

Case 3:00-cv-00705-CFD

Document 116

Filed 11/02/2004

Page 3 of 3

3 CERTIFICATION This is to certify that a copy of the foregoing Motion for Extension of Time was mailed on November 2, 2004 to the following: Sanford P. Dumain, Esq. Lee A. Weiss, Esq. Carlos A. Ramirez, Esq. Milberg Weiss Bershad & Schulman LLP One Penn Plaza - 49th Floor New York, NY 10119 David A. Slossberg Brian C. Fournier 147 North Broad Street P.O. Box 112 Milford, CT 06460 Michael J. Chepiga, Esq. Robert A. Bourque, Esq. William M. Regan, Esq. Laura D. Murphy, Esq. Simpson, Thacher & Bartlett, LLP 425 Lexington Avenue New York, NY 10017 Stanley A. Twardy, Jr., Esq. Thomas D. Goldberg, Esq. Terence J. Gallagher, Esq. Day, Berry & Howard, LLP One Canterbury Green Stamford, CT 06901

John B. Hughes Chief, Civil Division Federal Bar #Ct05289 U.S. Attorney's Office P.O. Box 1824 New Haven, CT 06510 (203) 821-3700