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

` Case 3: 0-cv-00380-DJS Document 154 Filed 06/OQ2004 Paget 0f2
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UNITED STATES DISTRICT COURT FIL E D
DISTRICT OF CONNECTICUT
————————~—- ZUUU ..
MARTA ABON : U_S D
Plai tiff zcrm. ACTION No; cvocpisgégiglcf COURT
V . . RD- ct
JOSEPH RECKO, STATE CREDIT :
ADJUST ENT BUREAU, INC., St :
JOHN F RRANTI `
Defend nts : June 1, 2004
DE ENDANT JOSEPH RECKO’S AND STATE CREDIT’S FIRST
‘ REQUE T FOR EXTENSION OF TIME TO RESPOND TO PLAINTIFF’S
FEE APPLICATION AND BILLS OF COSTS
Th Defendants, State Credit Adjustment Bureau, Inc., and Joseph 1
Recko, hereby make their first request for an extension and enlargement of
time in +¤hich to answer or otherwise respond to the Plaintiffs Fee
Application and Plaintiffs Bill of Costs dated May 19, 2004. The extension
so requejted is for a period through the thirtieth day following the
dispositiop of the Appeal of the Defendants now pending before the Second
Circuit Court of Appeals.
The Request is made for the following reasons:
1. lf the judgment in favor of the Plaintiff is upheld by the Second
Circuit, then the Plaintiff will seek additional counsel fees for
her services in connection with her defense of the Appeal.
2. If the judgment in favor of the Plaintiff is reversed, then the
award of fees and costs will be vacated, or null and void.
Thu , hearing the Plaintiffs claim for fees and costs before the

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Case 3: O-cv—OO380=DJS Document 1”64 Filed 06/82/$004 Page 2 Of 2
dispositi n of the Appeal will prove to be inconclusive, and will be an 5
unwise e penditure of time and effort.
3. Of note is that a prior application was made by the ‘Plaintiff’s
counsel ` 2002 prior to the taking of an appeal by the Defendants. The
Plaintiffs counsel then thought that such an application was necessary at
that time to preserve the rights of the Plaintiff. A similar extension to this
one was requested by the undersigned. The extension request was
granted. -
De endants’ Counsel has inq_uired of the Plaintiffs counsel whether
this requ st can be granted with her agreement. Counsel for the Plaintiff
does gg; onsent to this Request for Extension of Time.
THE DEFENDANT
JOSEPH RECKO &; STATE
CREDIT
By
Laure . Nadel
Of: Laurence . Nadel, P.C.
261 Bradley St.
New Haven, CT 06511
Tel. No: 77758356
Fed. No. CT. 05929
CERTIFICATION
I hereby certify that I have sent a copy on June l, 2004, of the foregoing First
Request by il'rst class mail, postage prepaid to Joanne Faulk E 3 von St., New
I·Iaven,CT0 511. .
L re c Nad l, Esq. .