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

Case 3:03-cv-00982-MRK

Document 18

Filed 12/29/2003

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UNITED STATES DISTRICT COURT DISTRICT OF CONNECTICUT JEFFREY JORDAN, PLAINTIFF, v. UNITED STATES OF AMERICA, DEFENDANT. : : : : : : : : :

CIVIL NO. 3:03CV00982 (MRK)

DECEMBER 29, 2003

UNOPPOSED MOTION, NUNC PRO TUNC, FOR EXTENSION OF TIME TO FILE REPLY BRIEF Pursuant to Rule 7 of the Local Rules of Civil Procedure for the District of Connecticut, the Defendant, United States of America, through its undersigned counsel, hereby respectfully requests that this Court grant an extension of time, nunc pro tunc, of twenty-one (21) days, from December 22, 2003 up to and including January 14, 2004, to file a reply brief in this case. This brief would be submitted in further support of the government's motion to dismiss filed on October 20, 2003, and in response to the Plaintiff's Memorandum in Opposition to that motion filed on December 8, 2003. The United States seeks this extension because undersigned counsel needs additional time to finalize the government's reply brief in light of the press of other business, including an oral argument at the Court of Appeals. Undersigned counsel makes this motion nunc pro tunc because the government's reply brief was due on December 22, 2003. Undersigned counsel did not seek this extension until now through inadvertence, and apologizes to the Court and opposing counsel for the oversight.

Case 3:03-cv-00982-MRK

Document 18

Filed 12/29/2003

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-2This is the first motion to extend this time limitation. Counsel for the plaintiff has no objection to the extension sought. Respectfully submitted, KEVIN J. O'CONNOR UNITED STATES ATTORNEY

LAUREN M. NASH ASSISTANT U.S. ATTORNEY P.O. BOX 1824 NEW HAVEN, CT 06508 (203) 821-3700 FEDERAL BAR # ct01705

Case 3:03-cv-00982-MRK

Document 18

Filed 12/29/2003

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CERTIFICATE OF SERVICE This is to certify that a copy of the within and foregoing Unopposed Motion, Nunc Pro Tunc, for Extension of Time to File Reply Brief, has been mailed, postage prepaid, on this 29th day of December, 2003, to: Kenneth A. Votre, Esq. Hurwitz, Cooper, Silverman & Votre, P.C. 667 State Street New Haven, CT 06511

LAUREN M. NASH ASSISTANT U.S. ATTORNEY P.O. BOX 1824 NEW HAVEN, CT 06508 (203) 821-3700 FEDERAL BAR # ct01705