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

Case 3:03-cv-00596-JBA

Document 50

Filed 01/08/2004

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UNITED STATES DISTRICT COURT DISTRICT OF CONNECTICUT TOM JAMES COMPANY, PLAINTIFF VS. J. TRACY GREEN, ET AL. DEFENDANTS MOTION FOR EXTENSION OF TIME Pursuant to D. Conn. L. Civ. R. 7 (b) (2), the defendants J. Tracy Green and Trace Apparel respectfully request that the Court grant them an extension of time of five (5) days to respond to the plaintiff's motion to compel electronic discovery. The undersigned is in the process of preparing a response to the motion, and is nearly complete. response. The defendant recognizes that the plaintiff has sought expedited The holiday period has made it difficult to finalize the defendant's January 7, 2004 CIVIL ACTION NO. 3:03cv00596 (JBA)

consideration of its motion.

As such, the plaintiff has not consented to this

extension. However, given that the relief sought by the plaintiff is unwarranted and unfounded, an additional five (5) days to formulate an appropriate response should be granted. This is the first motion for extension of time that has been filed in connection with this time limitation.

Case 3:03-cv-00596-JBA

Document 50

Filed 01/08/2004

Page 2 of 3

WHEREFORE, the defendants respectfully request that the Court grant this motion and permit an additional five (5) days to file response to the plaintiff's motion to compel, through and including January 13, 2004. THE DEFENDANTS J. TRACY GREEN TRACE APPAREL, LLC

By: ________//ss//____________________ Thomas A. Rouse, Fed. Bar No. ct06128 Peter S. Olson, Fed. Bar No. 16149 Pullman & Comley, LLC 850 Main Street, P.O. Box 7006 Bridgeport, CT 06601-7006 203.330.2000 Facsimile 203.576.8888 Their Attorneys

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Case 3:03-cv-00596-JBA

Document 50

Filed 01/08/2004

Page 3 of 3

CERTIFICATION Pursuant to Fed. R. Civ. P. Rule 5 (b), I hereby certify that a copy of the above was mailed on January 7, 2004 to all counsel and pro se parties of record. For the plaintiff TOM JAMES COMPANY: Thomas J. Finn Paula Cruz Cedillo Halloran & Sage LLP One Goodwin Square 225 Asylum Street Hartford, Connecticut 06103 860.522.6103 Facsimile 860.548.0006 _____________//ss//_________________ Thomas A. Rouse, Fed. Bar No. ct01326 Peter S. Olson, Fed. Bar No. ct16149

BPRT/67708.2/PSO/503104v1

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