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

Case 3:00-cv-00678-SRU

Document 85

Filed 03/28/2005

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UNITED STATES DISTRICT COURT DISTRICT OF CONNECTICUT O'KEEFE & ASSOCIATES, INC. Plaintiff VS. THEME CO-OP PROMOTIONS, INC. Defendant : : : : : MARCH 23, 2005 CIVIL ACTION NO. 3:00CV00678 (SRU)

MOTION FOR ENLARGEMENT Plaintiff files this Motion for Enlargement of Time up to and including May 31, 2005, to respond to Defendant's Motion to Strike and to file a Reply Memorandum in Support of its Motion for Summary Judgment / Motion to Dismiss. In support of this motion, Plaintiff cites the following: 1. time. 2. Counsel needs this additional time in order to research and brief the legal and Plaintiff's counsel is a sole practitioner who is inordinately busy at the present

factual issues involved. 3. Plaintiff's counsel has contacted Defendant's counsel who represents that he

has no objection to the granting of this motion. 4. This is the first request for an enlargement of time regarding these time limits.

Case 3:00-cv-00678-SRU

Document 85

Filed 03/28/2005

Page 2 of 2

THE PLAINTIFF

BY_____________________________ Francis D. Burke MANGINES & BURKE, LLC 11115 Main Street, Suite 708 Bridgeport, CT 06604 (203) 336-0887 Fed. Bar No. 18688

CERTIFICATION This is to certify that a copy of the foregoing was sent, via U.S. Mail, postage prepaid, this 23rd day of March 2005, to: David A. Ball, Esq. Cohen and Wolf, PC 1115 Broad Street Bridgeport, CT 06604

_______________________________ Francis D. Burke

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