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

Case 3:OO—cv—OO325-AVC Document 35 Filed 06/O9/2005 Page 1 of 2
UNITED STATES DISTRICT COURT
DISTRICT OF CONNECTICUT
SABER PETROLEUM LIMITED, §
§
Plaintiff, §
§ 3:00-CV-00325 (AVC)
- against - §
§
GLENCORE INTERNATIONAL, A.G., §
§
Defendant. §
MOTION FOR ENLARGMENT OF TIME N UNC PRO T UNC
Pursuant to Local Civil Rule 7(b), the Plaintiff, Saber Petroleum Limited, respectfully
moves for a one—vveek extension, Le., until June 10, 2005, to file its Response to this Court’s
Order to Show Cause dated May 18, 2005. There is good cause for the requested extension.
Plaintiffs response was originally due on June 3, 2005, on which date Attorney Charles S.
Cumming, co—counsel for Plaintiff, sent a letter brief to Chambers that explained vvhy this action
should not be dismissed. Thereafter, upon discussing that letter with Chambers, Plaintiff was
instructed to tile a more formal pleading together with this accompanying Motion for
Enlargement of Time Nunc Pro T unc. As instructed, with this motion Plaintiff also files its
Response to Order to Show Cause. This is the first such request for extension of time. Despite
diligent efforts to contact opposing counsel today, Le., Messrs. Lauer and Semmelman, the
undersigned counsel has not been able to ascertain opposing counsels’ position in respect of the
instant motion.
WHEREF ORE, Plaintiff respectfully moves that this Court extend the deadline to file a
Response to Order to Show Cause until June 10, 2005.

Case 3:OO—cv—OO325-AVC Document 35 Filed 06/O9/2005 Page 2 of 2
Dated: Southport, Connecticut
I une 8, 2005
Respectfully Submitted,
The Plaintiff,
SABER PETROLEUM LIl\/IITED
By; . l gfi ··*’ . .,l- - :·
Charles E. Murphy (CT 1 784)
Patrick F. Lennon (CT 11950)
TISDALE & LENNON, LLC
10 Spruce St.
Southport, CT 06490
TL@tisdale—lennon.com
OF COUNSEL:
Michael G. Chalos (Fed. Bar No. MC3939)
Charles S. Cumming (Fed. Bar No. CC4l60)
FOWLER, RODRIGUEZ & CHALOS
366 Main Street
Port Washington, NY 11050
CERTIFICATION OF SERVICE
I hereby certify that on this _g_m day of June 2005, I mailed a copy of the foregoing
pleading, postage prepaid, to the following counsel of record:
Curtis, Mallet—Prevost, Colt & Mosle
101 Park Ave., 35th Floor
New York, NY 10178
Attn: Elliot Lauer, Esq.
Jacques Semmelman, Esq.
` arles E. Murphy ‘5l‘'` I `P