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

Case 3:00-cv-02009-EBB

Document 64

Filed 03/01/2005

Page 1 of 3

UNITED STATES DISTRICT COURT DISTRICT OF CONNECTICUT UNITED STATES OF AMERICA, : : Plaintiff, : : v. : : $662,310.79 IN UNITED STATES : CURRENCY SEIZED FROM ACCOUNT : NUMBER 100080907, HELD IN THE : NAME OF FRANKLIN CREDIT : SERVICES, INC., AT FIRST : TENNESSEE BANK, FRANKLIN, : TENNESSEE, ET AL : : Defendants. :

Civil No. 3:00CV2009 (EBB)

March 1, 2005

MOTION FOR EXTENSION OF TIME The Plaintiff, United States of America, hereby moves for its first extension of time of forty-five days to file a response to Receiver-Claimants Motion for Summary Judgment. Undersigned counsel for the Plaintiff has been unable to complete a response by the due date of March 2, 2005, due to the absence of the Assistant U.S. Attorney assigned to the case who is out on maternity leave. Assistant U.S. Attorney Turbert is due back in the office on March 14, 2005, and the forty-five day extension will allow her thirty days to prepare and file a response. Douglas Schmidt, Counsel for International Financial Services Life Insurance Company, and of behalf of Franklin Protective Life Insurance Company, Family Guaranty Life Insurance Company, First National Life Insurance Company, Franklin American Life Insurance Company, Farmers and Ranchers Life Insurance Company, and Old Southwest Life Insurance

Case 3:00-cv-02009-EBB

Document 64

Filed 03/01/2005

Page 2 of 3

Company, has been contacted and has no objection to this request. Respectfully submitted, KEVIN J. O'CONNOR UNITED STATES ATTORNEY

JOHN B. HUGHES CHIEF, CIVIL DIVISION UNITED STATES ATTORNEYS OFFICE P.O. BOX 1824 NEW HAVEN, CT 06510 FEDERAL BAR # ct05289

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Case 3:00-cv-02009-EBB

Document 64

Filed 03/01/2005

Page 3 of 3

CERTIFICATE OF SERVICE This is to certify that a copy of the within and foregoing Motion for Extension of Time has been mailed, postage prepaid, this 1st day of March, 2005, to: Susan B. Loving, Esq. Lester, Loving & Davies 1505 Renaissance Blvd. Edmond, OK 73013-3018 Douglas J. Schmidt, Esq. Blackwell Sanders Peper Martin, LLP 2300 Main, Suite 1100 Kansas City, MO 64108 Andrew B. Campbell, Esq. Wyatt, Tarrant & Combs 2525 W. End Avenue, Suite 1500 Nashville, TN 37203 Douglas S. Skalka, Esq. Neubert, Pepe & Monteith 195 Church Street, 13th Floor New Haven, CT 06510-2026 Charles G. Copeland, Esq. Copeland, Cook, Taylor & Bush 200 Coucourse 1062 Highland Colony Parkway, Suite 200 Ridgeland, MS 39157 Steve A. Uhrynowycz, Esq. 1200 West Third Street, Room 340 Little Rock, Arkansas 72201-1904

JOHN B. HUGHES CHIEF, CIVIL DIVISION ASSISTANT U.S. ATTORNEY

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