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

Case 3:03-cv-00459-PCD

Document 39

Filed 10/22/2004

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UNITED STATES DISTRICT COURT DISTRICT OF CONNECTICUT CROSSROADS COMMUNICATIONS OF OLD SAYBROOK, LLC, Plaintiff, VS. TOWER VENTURES, INC., Defendant. : : : : : : : : :

CIVIL NO. 3:03CV459(PCD)

OCTOBER 21, 2004

FINAL CONSENT MOTION TO MODIFY BRIEFING SCHEDULE Plaintiff Crossroads Communications of Old Saybrook, LLC ("Crossroads") hereby moves to modify the briefing schedule for opposition and reply papers relating to defendant's motion for summary judgment. follows: 1. Defendant served a summary judgment motion, by mail, on Pursuant to the Court's order, plaintiff's In support thereof, the parties state as

August 9, 2004.

response was due on October 8, 2004, and defendant's reply is due on October 29, 2004. 2. The deadlines requested in plaintiff's last motion were

based on counsel's assumption that counsel would be able to work during that time with plaintiff's principal, Mr. Don DeCesare, on the affidavit to be submitted with plaintiff's response, and on the factual responses to defendant's Rule 56(a)(1) statement. Shortly

after the filing of that motion, counsel learned that, because of Mr. DeCesare's schedule, more time should have been requested.

Case 3:03-cv-00459-PCD

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Filed 10/22/2004

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3.

Rather than burden the court with further motion

practice, counsel for plaintiff and defendant attempted to work out an agreement among themselves for exchange of papers, which would result in the entire summary judgment pleading and briefing package being filed with the court by October 29th, the original date fixed by the court. Plaintiff's counsel has been working diligently this

week with Mr. DeCesare to finalize plaintiff's response, but will be unable to serve the papers before October 25th, which unfortunately would not give defendant's counsel adequate time to file a reply. 4. Based on this, plaintiff respectfully requests a further,

final extension to October 25, 2004, for the service of responsive papers; and a one-week extension to November 5, 2004 for the filing of defendant's reply papers. This modification will delay by only

a week the date by which the matter is fully briefed and submitted to the court. date. 5. Elizabeth R. Leong, Esq., counsel for the defendant, does The parties Plaintiff will not seek further extension of this

not object to the requested extension of time.

previously filed a joint motion to modify the deadlines for responding to summary judgment motion(s), and three prior motions for extension were filed by the plaintiff.

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Case 3:03-cv-00459-PCD

Document 39

Filed 10/22/2004

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WHEREFORE, the plaintiff requests modification of the briefing schedule as requested above. THE PLAINTIFF CROSSROADS COMMUNICATIONS OF OLD SAYBROOK, LLC By____________________________________ David T. Grudberg, ct01186 JACOBS, GRUDBERG, BELT & DOW, P.C. 350 Orange St. P.O. Box 606 New Haven, CT 06503 Ph.:(203) 772-3100 Fax:(203) 772-1691 Email: [email protected]

CERTIFICATION I hereby certify that a copy of the foregoing was faxed and mailed first class, postage pre-paid, on October 21, 2004 to: Steven R. Humphrey, Esq. Elizabeth R. Leong, Esq. Marion B. Manzo, Esq. Robinson & Cole, LLP 280 Trumbull St. Hartford, CT 06103-3597 ____________________________________ David T. Grudberg

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