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

Case 3:00-cv-00678-SRU

Document 60

Filed 08/19/2004

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

MOTION FOR ENLARGEMENT OF THE DISPOSITIVE MOTIONS DEADLINE Plaintiff files this Motion for Enlargement of Time for 30 days, up to and including September 29, 2004, of the dispositive motions deadline. In support of this motion, Plaintiff cites the following: 1. Plaintiff's Motion to Amend Complaint and Defendant's Objection thereto is

currently pending. 2. Counsel needs this additional time in order to research and brief the legal and

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 second request for an enlargement of time regarding this time limit,

apart from previous requests regarding discovery and other deadlines.

Case 3:00-cv-00678-SRU

Document 60

Filed 08/19/2004

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 August 2004, to: David A. Ball, Esq. Cohen and Wolf, PC 1115 Broad Street Bridgeport, CT 06604

_______________________________ Francis D. Burke

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