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

Case 3:00-cv-00678-SRU

Document 76

Filed 12/16/2004

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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. _______________________________ DECEMBER 16, 2004

DEFENDANT'S MOTION FOR EXTENSION OF TIME Defendant, Theme Co-Op Promotions, Inc., moves for an extension of time of sixty (60) days, through and including February 22, 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. Defendant faces a deadline of December 23, 2004 to file an opposition to

Plaintiff's motion. 3. Defendant requires an extension of time in order to fully address the matters

raised in plaintiff's motion.

Case 3:00-cv-00678-SRU

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Filed 12/16/2004

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4.

The undersigned is lead counsel for numerous municipalities who are contesting

an application by Connecticut Light and Power Co. and United Illuminating Co. to construct a $600 million high-powered transmission line between Norwalk and Middletown. The application is pending before the Connecticut Siting Council, Docket No. 272, which has scheduled evidentiary hearings during the weeks of January 10, 2005 and January 17, 2005. For this reason as well, Defendant requires the requested extension in this case. 5. The undersigned discussed this motion with counsel for the Plaintiff, who has no

objection to the granting of this motion. 6. This is the Defendant's first request for an extension of this deadline.

WHEREFORE, Defendant moves for an extension of time of sixty (60) days, through and including February 22, 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

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Filed 12/16/2004

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CERTIFICATION I hereby certify that on this 16th day of December 2004, 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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