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

Case 3:03-cv-00459-PCD

Document 37

Filed 09/24/2004

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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)

SEPTEMBER 24, 2004

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 is due on September 28, 2004, and defendant's reply is due on October 13, 2004. 2. Counsel had hoped to be able to conclude the responsive However, daily court obligations have further

papers this week.

delayed progress on the response, and further time is also needed to meet with Mr. Don DeCesare, plaintiff's principal, to review and finalize the affidavit to be submitted with plaintiff's response. It will not be possible to complete this before the current

Case 3:03-cv-00459-PCD

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Filed 09/24/2004

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September 28th deadline, and accordingly, plaintiff needs additional time to prepare, finalize and serve plaintiff's response. 3. Defendant's counsel is scheduled to be away from her This time period

office from October 13th through October 17th.

would include the period for the preparation and filing of defendant's reply papers, and accordingly the parties have requested a slightly longer time for defendant's reply than would otherwise be provided by the rules and supplemental order. 3. For these reasons, plaintiff requests a modification of Plaintiff's memorandum and other

the briefing schedule as follows:

papers in opposition to summary judgment to be filed by October 8, 2004; any reply papers in further support of defendant's motion, and responding to plaintiff's memorandum, to be filed by October 29, 2004. 4. Marion B. Manzo, Esq., counsel for the defendant, does The parties

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 two prior motions for extension were filed by the plaintiff.

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Case 3:03-cv-00459-PCD

Document 37

Filed 09/24/2004

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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 September 24, 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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