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

Case 3:00-cv-00678-SRU

Document 72

Filed 11/29/2004

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UNITED STATES DISTRICT COURT DISTRICT OF CONNECTICUT O'KEEFE & ASSOCIATES, INC. Plaintiff VS. THEME CO-OP PROMOTIONS, INC. Defendant : : : : : NOVEMBER , 2004 CIVIL ACTION NO. 3:00CV00678 (SRU)

MOTION FOR ENLARGEMENT Plaintiff files this Motion for Enlargement of Time up to and including December 14, 2004, to respond to Defendant's Motion to Dismiss. The current deadline is November 30, 2004. 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 this motion. 4. This is the third request for an enlargement of time regarding this time limit.

Case 3:00-cv-00678-SRU

Document 72

Filed 11/29/2004

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 _______ day of November 2004, to: David A. Ball, Esq. Cohen and Wolf, PC 1115 Broad Street Bridgeport, CT 06604

_______________________________ Francis D. Burke

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