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

Case 3:00-cv-00678-SRU

Document 79

Filed 02/22/2005

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UNITED STATES DISTRICT COURT DISTRICT OF CONNECTICUT _______________________________ O'KEEFE & ASSOCIATES, INC. v. Plaintiffs, Civil Action No. 3:00-CV-678 (SRU)

THEME CO-OP PROMOTIONS, INC. Defendants. _______________________________ FEBRUARY 22, 2005

DEFENDANT'S MOTION FOR EXTENSION OF TIME Defendant, Theme Co-Op Promotions, Inc., moves for an extension of time of fourteen (14) days, through and including March 8, 2005, to file an Opposition to Plaintiff's Motion to Dismiss and/or for Summary Judgment. In support of this motion, Defendant respectfully represents: 1. On November 29, 2004, Plaintiff filed a Motion to Dismiss and/or for Summary

Judgment together with a 38-page Memorandum of Law. 2. motion. 3. Defendant requires an extension of time in order to fully address the matters Defendant faces a deadline of February 22, 2005 to file an opposition to Plaintiff's

raised in plaintiff's motion.

Case 3:00-cv-00678-SRU

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Filed 02/22/2005

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4.

The undersigned discussed this motion with counsel for the Plaintiff, who has no

objection to the granting of this motion. 5. This is the Defendant's second request for an extension of this deadline.

WHEREFORE, Defendant moves for an extension of time of fourteen (14) days, through and including March 8, 2005, to file an Opposition to Plaintiff's Motion to Dismiss and/or for Summary Judgment.

THE DEFENDANT, THEME CO-OP PROMOTIONS, INC. By_____________________________ David A. Ball, Esq. Fed. Bar No. ct10154 Cohen and Wolf, P.C. 1115 Broad Street Bridgeport, CT 06604 Tel. No. (203) 368-0211

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Case 3:00-cv-00678-SRU

Document 79

Filed 02/22/2005

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CERTIFICATION I hereby certify that on this 22nd day of February 2005, a copy of the foregoing motion was mailed via First Class Mail, postage prepaid, to the following: Francis D. Burke, Esq. Mangines & Burke LLC 1115 Main Street Suite 708 Bridgeport, CT 06604 ____________________________ David A. Ball, Esq.

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