Free Motion for Extension of Time to File Response/Reply to Motion - District Court of Connecticut - Connecticut

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, ., Case 3:03-cv-00193-MRK Document 88 Filed 07/12/2004 Page 1 ··»·
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UNITED STATES DISTRICT COURT "` _
DISTRICT OF CONNECTICUT , i
MARIAN D1:BoRA1»1 MILLER, QI »·/·· 1
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Pnamurr, '_, l.,5_ S
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VS. CIV NO. 1
3:03CV 0193 (MRK) 1
EDWARD D. JONES & CO., L.P.,
MICHAEL MAHONEY, MICHAEL
CUMMINS, BARBARA MOSCA, and
STEVEN RARICK,
Defendants.
July 9, 2004
` DEFENDANTS’ UNOPPOSED MOTION
FOR ENLARGEMENT OF TIME
COME NOW Defendants, Edward D. Jones & Co., L.P., Michael Cummins, I
Barbara Mosca, and Steven Rarick (hereinafter collectively "Defendants”), pursuant to
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Rule 26 of the Federal Rules of Civil Procedure, and Local Rule 7(d), and, for the reasons
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outlined below, move for an Order extending Defendants’ date for filing their reply briefs i
in support of their motions for summary judgment by seven (7) calendar days from i
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Monday, July 12, 2004 to Monday, July 19, 2004;
This unopposed motion is with consent of opposing counsel, Mr, Vlad Spitzer,
and does not change or effect any other date on the Scheduling Order.
These four Defendants each filed Motions for Summary Judgment on April 30, i
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2004. Plaintiff requested and received extensions of time up to June 25, 2004 within
which to file Plaintiffs Opposition to Defendants’ Motions for Summary. Under Local S
Rule 7(d), Defendants’ reply briefs are due Monday, July 12, 2004. Because of the I
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’ ’ Case 3:03-cv-00193-MRK Document 88 Filed 07/12/2004 Page 2 of 4 V

number of separate motions, four, and the length of Plaintiffs briefs in opposition to the
four motions for summary judgment, Defendants respectfully request a one (1) week
extension of time up to and including Monday July 19, 2004 within which to file their I
reply briefs in support of their motions for summary judgment. Defendants anticipate that
their reply briefs will assist the Court by clarifying and narrowing the focus of the
motions and legal issues.
For the Court’s convenience, the Defendants have attached a proposed Order q
regarding their Motion for Enlargement. l
WHEREFORE, Defendants move the Court for an Order modifying the
Scheduling Order as set forth above.
Respectfully submitted,
THE DEFENDANTS: Edward Jones, I
Michael Cummins, Barbara Mosca and i
Steven Rarick
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By: ` . l
Michael N. LaVelle, Esq. j
Federal Bar No. 06170
Pullman & Comley, LLC
850 Main Street, P.O. Box 7006
Bridgeport, CT 06601-7006
(203) 30-2000
By: f R
Fr d A. Ricks, Jr., Esq. j
Federal Bar No.: ct25435 l
Harris Dowell Fisher & Harris, L.C.
15400 South Outer Forty, Suite 202
St. Louis, Missouri 63017 {
(636) 532-0300 j
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I Case 3:03-cv-00193-MRK Document 88 Filed 07/12/2004 Page 3 of 4
I CERTIFICATE OF SERVICE N
This is to certify that a copy of the foregoing was mailed this 9th day of July,
2004, postage prepaid by U.S. Mail to the following persons:
Peter E. Gillespie, Esq.
Attorney at Law
46 Riverside Avenue
Westport, CT 06880
(203) 227-7000 {
Vlad Spitzer and Huma Khan, Esq.
Spitzer & Brey, LLC
239 Main Street, 2nd Floor I
Westport, CT 06880
(203) 226— 266 Ext. 14
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r Case 3:03-cv-00193-MRK Document 88 Filed 07/12/2004 Page 4 of 4
UNITED STATES DISTRICT COURT
DISTRICT OF CONNECTICUT
MARIAN DEBORAH MILLER,
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Plaintiff, l
vs. CIV N0.
3:03CV 0193
EDWARD D. JONES & CO., L.P.,
MICHAEL MAHONEY, MICHAEL ‘
CUMMINS, BARBARA MOSCA, and y
STEVEN RARICK, l
Defendants.
ORDER
The Defendants’ Motion For Enlargement of Time dated July 9, 2004 is hereby
GRANTED. Defendants shall file their Reply briefs in support of their Motions For
Summary Judgment in this case on or before Monday, July 19, 2004. {
IT IS SO ORDERED l
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Mark R. Kravitz a
United States District Judge
Dated at New Haven, Connecticut:
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