Free Motion for Miscellaneous Relief - District Court of Connecticut - Connecticut

Case 3:03-cv-00459-PCD

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Filed 09/17/2004

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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 17, 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 20, 2004, and defendant's reply is due on October 5, 2004. 2. Counsel's progress on the motion response has been

further delayed by court obligations, and as a result will be unable to serve responsive papers by September 20th. Accordingly,

plaintiff needs additional time to prepare, finalize and serve plaintiff's response. 3. For these reasons, plaintiff requests a modification of Plaintiff's memorandum and other

the briefing schedule as follows:

Case 3:03-cv-00459-PCD

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papers in opposition to summary judgment to be filed by September 28, 2004; any reply papers in further support of defendant's motion, and responding to plaintiff's memorandum, to be filed by October 13, 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 one prior motion for extension was filed by the plaintiff. 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]

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Case 3:03-cv-00459-PCD

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CERTIFICATION I hereby certify that a copy of the foregoing was faxed and mailed first class, postage pre-paid, on September 17, 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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