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

H nlllnn _ Case 3:00-cv-00871-CFD Document 122 Filed 1 1/24/2004 Page 1 of 3 [
n UNITED STATES DISTRICT COURT
DISTRICT OF CONNECTICUT
3: O0 cu WZ! (Leno CASJQ
GREYSTONCE COMMUNITY : CIVIL ACTION NO.
REINVESTMENT ASSOCIATES, INC., : 3:02 CV 1703 (CFD)
Plaintiff] ‘·
V. -
BEREAN CAPITAL, INC.,
Defendant. NOVEMBER 24, 2004
MOTION FOR EXTENSION OF TIME ON CONSENT
Pursuant to Rule 7(b) of the Local Civil Rules of the United States District Court for the
District of Connecticut, the defendant, Berean Capital, Inc. ("Berean"), respectfully requests an
extension of time often ( 10) days in which to respond to the plaintiff s, Greystone Community
Reinvestment Associates, Inc. ("Greystone"), Request for Admissions, dated October 26, 2004, I g
up to and including December 6, 2004. Beran further requests an extension of time of five (5)
days in which to respond to Plaintiffs First Request for Inteirogatories, dated November 1, A
2004, upto and including December 6, 2004. I
As good cause for the requested extension of time, Berean submits that, despite its
diligence in preparing responses to Greystone’s discovery requests, the additional time is
HBCESSBIY to 3.dGC]_`l13.tB1y evaluate and BIIRIYZC tI1€ HIIHICTOUS I`CqU€StS. Berean needs IIIG
additional time to gather responsive informationand to adequately prepare appropriate responses
to the interrogatories and ninety-seven (97) requests for admissions.
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Case 3:00-cv-00871-CFD Document 122 Filed 11/24/2004 Page 2 of 3
This is Berean’s first request for an extension of time with respect to this matter. Counsel J
for Greystone has consented to the requested extension. {
WHEREFORE, the defendant, Berean Capital, Inc., respectfully requests that the Court
grant this Motion for Extension of Time on Consent, dated November 24, 2004, and extend the i
time in which to respond to Greystone’s Request for Admissions and First Request for
C Interrogatories, up to and including December 6, 2004. A
Dated: November 24, 2004 RESPECTFULLY SUBMITTED,
Hartford, Connecticut `
THE DEFENDANT,
BEREAN CAPITAL, INC.
By: ( I
Thomas J. Finn
Federal Bar No.: ct 20929 I i
Paula Cruz Cedillo i
Federal Bar No.: ct 23485 E
McCARTER & ENGLISH LLP -
CityP1ace I .
185 Asylum Street .
Hartford, Connecticut 06103 ` B
Tei: $60.2756700 I `
Fax: 860.724.3397 . l
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_ . Case 3:00-cv-00871-CFD Document 122 Filed 11/24/2004 Page 3 of 3 I
CERTIFICATION 1
This is to certify that on this 24th day of November 2004, a copy of the foregoing was
mailed, postage prepaid, to:
Eliot B. Gersten, Esq.
John J. Robacynski, Esq.
Allan W. Koerner, Esq.
Gersten & Clifford
214 Main Street
Hartford, Connecticut 06106
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Paula Cruz Cedillo
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