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

Case 3:03-cv-00596-JBA

Document 60

Filed 02/02/2004

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UNITED STATES DISTRICT COURT DISTRICT OF CONNECTICUT TOM JAMES COMPANY, PLAINTIFF VS. J. TRACY GREEN, ET AL. DEFENDANTS MOTION FOR EXTENSION OF TIME Pursuant to D. Conn. L. Civ. R. 7 (b) (2), the defendant J. Tracy Green (hereinafter, "Green") hereby moves that the Court enlarge the time set in the Report of Parties Planning Meeting dated August 12, 2003 [Doc. No. 13], at ¶ V (c)(a), for the provision of a damages analysis. Green has propounded discovery requests on Tom James, that Tom James has refused to comply with. Green has filed this day a motion to compel responses to certain questions that involve damages on Green's counterclaim. Without responses to the discovery requests, Green cannot prepare his damages analysis. Accordingly, Green respectfully requests that the Court enlarge the time for him to provide his damages analysis for thirty (30) days, through and including February 2, 2004 CIVIL ACTION NO. 3:03cv00596 (JBA)

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Case 3:03-cv-00596-JBA

Document 60

Filed 02/02/2004

Page 2 of 3

March 1, 2004. Counsel for Tom James consents to this request. WHEREFORE, for the foregoing reasons, Green respectfully requests that the court enlarge the time for him to provide a damages analysis through and including March 2, 2004.

THE DEFENDANTS/ COUNTERCLAIM PLAINTIFFS J. TRACY GREEN TRACE APPAREL, LLC

By: ______________________________ Thomas A. Rouse, Fed. Bar No. ct01326 Peter S. Olson, Fed. Bar No. ct16149 Pullman & Comley, LLC 850 Main Street P.O. Box 7006 Bridgeport, CT 06601-7006 203.330.2000 Facsimile 203.576.8888 Their Attorneys

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Case 3:03-cv-00596-JBA

Document 60

Filed 02/02/2004

Page 3 of 3

CERTIFICATION Pursuant to Fed. R. Civ. P. Rule 5 (b), I hereby certify that a copy of the above was mailed on February 2, 2004 to all counsel and pro se parties of record. For the plaintiff TOM JAMES COMPANY: Thomas J. Finn Paula Cruz Cedillo Halloran & Sage LLP One Goodwin Square 225 Asylum Street Hartford, Connecticut 06103 860.522.6103 Facsimile 860.548.0006 ______________________________ Thomas A. Rouse, Fed. Bar No. ct01326 Peter S. Olson, Fed. Bar No. ct16149

BPRT/67708.2/PSO/505998v1

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