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

Case 3:00-cv-00325-AVC Document 38 Filed 06/09/2005 Page 1 of 3
UNITED STATES DISTRICT COURT
DISTRICT OF CONNECTICUT

Plaintiff, 3:00 CV. 325 (AVC)
-against-
GLENCORE INTERNATIONAL, A.G.,
Defendant. June 9, 2005
MOTION FOR EXTENSION OF TIME
Defendant, Glencore International, A.G. ("Intemati0nal"), by and through their
undersigned counsel of record, hereby move for a 7-day extension of time in which to respond to
Saber Petroleum Ltd.’s ("Saber") motion requesting that the Court withdraw its April 4, 2005
Order dismissing the above-captioned case.
On May 18, 2005, the Court ordered Saber to show cause by June 3, 2005, why
the judgment dismissing this case should be reopened (the "May 18 Order"). On June 3, 2005,
Saber filed a letter submission. The May 18 Order allowed for Intemational to file a response on
or before June 17, 2005.
On June 9, 2005, counsel for plaintiff infonned the undersigned counsel of record
that he had filed a motion on June 8, 2005, as a substitute submission to the Court. The
undersigned counsel of record hereby moves for an extension of time until June 24, 2005, to
respond to plaintiff s June 8, 2005 motion. This is the first request for an extension of time.
Counsel for plaintiff has been contacted and has stated no objection to the granting of this
motion.
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Case 3:00-cv-00325-AVC Document 38 Filed 06/09/2005 Page 2 of 3
WHEREF ORE, the undersigned respectfully requests the granting of this motion.
Dated: Stamford, Connecticut
June 9, 2005
Respectfully submitted,
DEFENDANT
GLEN ¤··· - . ,
By: ·"‘$,, Ag 1
Peter E. Fleming, III (ctl 986)
CURTIS, MALLET-PRE OST, COLT & MOSLE
LLP
695 East Main Street
Stamford, CT 06901
Telephone: (203) 359-6200
Facsimile: (203) 328-2617
Eliot Lauer (ctl 5323)
Jacques Semmelman (ct15322)
Admitted Pro Hac Vice
CURTIS, MALLET-PREVOST, COLT & MOSLE
LLP
101 Park Avenue
New York, New York 10178-0061
(212) 696-6000
CERTIFICATE OF SERVICE
This is to certify that a copy of the foregoing Motion for Extension of Time was
served by first class mail this 9th day of June, 2005, upon the following counsel of record.
Charles S. Cumming, Esq.
Fowler, Rodriguez & Chalos
366 Main Street
Port Washington, NY 11050
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Case 3:00-cv-00325-AVC Document 38 Filed 06/09/2005 Page 3 of 3
Chuck Murphy, Esq.
Patrick Lennon, Esq.
Tisdale & Lennon, LLC
10 Spruce Street
Southport, CT 06490
Peter E. Fleming, III E
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