Free Motion for Extension of Time - District Court of Delaware - Delaware

Case 1 :06-cv—00276-GIVIS Document 4 Filed 05/26/2006 Page 1 of 4
IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF
DELAWARE
ALBU TRADING, INC.
Plaintiff, ) C.A. No. 06-276 GMS
CHARLES C. ALLEN III
(President of Allen Family Foods, Inc.)
Defendant )
I I. E D
T°» FVEAY T20 2000
The Honorable Judge Gregory M. Sleet
U.S. DI STRICT COURT
DISTRICT OF DELAWARE
" I
APPLICATION FOR EXTENSION OF TIME
Your Honor,
As the undersigned Peter Albu, representing Albu Trading, Inc. as
president, I am applying for an extension of time to obtain a counsel in the
above mentioned case, taking in consideration a specific personal situation
that I have which has brought on time constraints.
I am employed in two full time jobs, that, in fact, constitute the main
source of my income. I am a building maintenance worker, involved in 80
hours of work, weekly. I work every day ofthe week. I prove this allegation
with the attached pay-check stubs.

Case 1:06-cv—00276-Gl\/IS Document 4 Filed 05/26/2006 Page 2 of 4
2
Because of my inflexible schedule, I need additional time to find a
lawyer. In the past interval of time I tried to find a lawyer in Delaware. I sent
to a multiple number of lawyers letters with the copy of the complaint with
the exhibits, and await a response.
Both of my jobs are included in the Union, and by the Union building
agreement, I am entitled to receive my vacation after June l, following a
drive to Wilmington to search more actively for a lawyer. I reside in New
York.
I am committed to continue this civil action, and I apologize to Mr.
Charles C. Allen III, because I instituted this lawsuit against him, as an
individual person; but acting, accordingly, I considered this the last judicial
resource that has remained in recovering material and morale from the
damage.
Because of the status of limitation, that intervened on April 29, 2006, I
will ask, Your Honor, reverentially, to observe that, through the dismissal of
this action at this stage, a new civil action can not be instituted again and
therefore I ask you to strongly consider this appeal.
Thank you for your understanding.
Respectfully submitted,

Peter Albu fPresident of Allllu qradilg, Inc.
.2 / '
._ I ( c F
’
May 25, 2006 ( ~

Case 1:06-cv—00276-Gl\/IS Document 4 Filed 05/26/2006 Page 3 of 4
IN TI-IE UNITED STATES DISTRICT COURT _
FOR THE DISTRICT OF DELAWARE —
ALBU TRADING, INC.
Plaintiff
l : Civil Action No. 06-276 GMS
CHARLES C. ALLEN, III
Defendant
Q R D E B
WHEREAS, on Ap1il27, 2006, 21 complaint was tiled in this case (DI. 1);
WHEREAS, “a corporation may appear in the federal courts only through licensed
counsel"‘;
IT IS HEREBY ORDERED that:
The plaintiff shall have 30 days from the date of this Order within which to obtain
cotmscl. Failure to obtain counsel may result in the dismissal of this action.
Dated: May gf , 2006
UNIT D ST TES DIST CT I E
' Rowland v. Calnornia Mens Colony, 506 U.S. 194, 202 (1993); Carefirsr 0fMaryZc1nd,
Inc. v. Care FirstTrc1n.$p0rtcztion, Inc., No. Civ. A. 02-229(MPT), 2002 WL 31500927, at * 3 (D.
Del. Nov. 1,2002).

Case 1:06-cv—00276-G|\/IS Document 4 Filed 05/26/2006 Page 4 of 4
CERTIFICATE OF SERVICE
I, the undersigned Peter Albu, President of Albu Trading, Inc/ Plaintiff in
civil action 06-276 GMS — declare under penalty of perjury that a copy of
annexed Application for Extension of Time was sent by certified mail to Mr.
Charles C. Allen / at the main place of business Mr. Carles C. Allen,
President of Allen Family Foods, Inc, 126 N. Shirplay Street, Seaford, DE
19973 —today May 25, 2006.
The mail office receipt is amiexed.
Peter Awfuf C

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