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

{_ ase 3:03-cv-004565MRK Document 58 Filed O1 /1 O/2005 Page 1 of 2 ci
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UNITED STATES n1STR1§?r‘td0URT‘
DISTRICT OF CONNE TICUT KD .5. j\
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KERIN CARMODY, : ]_\\%°.\ ~Ti§\/IL l
PLAINTIFF : 3 :Q3Q·\#§Q045·6q{i\7lRK) .
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KOHIJS DEPARTMENT STORES, INC, : JANAURY 07, 2005 J
DEFENDANT l
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JOINT PARTIES MOTION FOR EXTENSION OF THE PRETRIAL DEADLINES {
Pursuant to Local Rule 7 (b) and FRCP Rule 6 (b) the Plaintiff, by counsel, respectfully R
request an extension of the deadlines with respect to the tiling of the parties joint trial K
memorandum until January 13, 2005. In support of this motion, the Plaintiff represents the
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following: {
l. The current scheduling orders call for the completion and tiling of the joint trial
memorandum by January 10, 2004. Z
2. Trial counsel for the Plaintiff has been experiencing flu-like which symptoms which
increased in intensity subsequent to the telephonic conference with the court on January 05,
2005.
3. The additional time is necessary in order for the completion ofthe parties joint trial
memorandum.
4. The Defendant has been consulted and no objection to this request has been voiced at L
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this time.
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·- ase 3:O3—cv—OO45 -\|\/IRK Document 58 Filed O1/10/2005 Page 2 of 2
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WHEREF ORE, the plaintiff requests the Court extend the time for the filing of the Joint r
Parties' Pretrial Memorandum order deadline until J anuary 13, 2005.
THE PLAINTIFF,
KERIN CARMODY
BY "`
RICHARD H. GREENE, CT 08905
431 HOWE AVENUE, PO BOX 2042
SHELTON, CT 06484 1
(203) 924-9361 Fax: (203) 922-1636
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CERTIFICATION
This is to certify that a copy of the foregoing request for extension of time I
was sent pursuant to local rule on January 07, 2005, to all counsel and pro se
parties of record:
Barry Beletsky, Esq. 1
David Baker, Esq. 1
Riccio & Beletsky LLC
310 Main Street, Suite 2B
East Haven, CT 06512
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y Richard H. Greene 1
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