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

Case 3:03-cv-00559-AVC

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UNITED STATES DISTRICT COURT DISTRICT OF CONNECTICUT

PUTNAM PARK ASSOCIATES, Plaintiff

: :

CIVIL ACTION NO. 3:03CV559 (A VC)

V.
PAYCHEX,INC., Defendant

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: : JANUARY 8, 2004

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MOTION FOR EXTENSION OF TIME

Pursuantto F. R. C. P. Rule 7 and L. Civ. R. 7(b), plaintiff Putnam Park Associateshereby respectfully moves this Court for a 30-day extensionof time, to and including February 9,2004, for the parties to file a Joint Trial Memorandum in compliance with the Court's Pretrial Order dated December8, 2003. As and for good cause,plaintiff statesthat the parties have recently reachedan oral agreement settle this matter but that insufficient time remainsbefore the current filing deadline of to January8, 2004, to finalize their agreement;and that plaintiff believes that thirty (30) dayswill be sufficient time to finalize an agreementand seekdismissal of this action. The parties have not previously requestedany extensionof time with respectto the Joint Trial Memorandum.

Case 3:03-cv-00559-AVC

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Document 26

Filed 01/08/2004

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Movant's counselhas inquired of counsel for the defendant,and representsthat there is

agreement this motion. to PUTNAM PARK ASSOCIATES, PLAINTIFF

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Michelle M. Seery t24101) Baker O'Sullivan & Bliss PC Suite 100, 100 Great Meadow Rd. Wethersfield, CT 06109 (860) 258-1993 (860) 258-1993 Its Attorneys

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Case 3:03-cv-00559-AVC

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Filed 01/08/2004

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CERTIFICATION
I herebycertify that on January8,2004, a copy of the foregoing Motion for Extension of Time was mailed, postageprepaid, to defendant'scounselof record asfollows: Edward Diaz, Esq. Holland & Knight LLP 222 Lakeview Avenue Suite 1000 West Palm Beach, FL 33401 Jodi Zils Gagne, Esq. Pepe & Hazard, LLP Goodwin Square 225 Asylum Street Hartford, CT 06103-4302

Alan Robert Baker (ct05623)

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