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

Case 3:00-cv-00835-CFD

Document 507

Filed 07/03/2007

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UNITED STATES DISTRICT COURT DISTRICT OF CONNECTICUT

INDYMAC BANK, F.S.B. Plaintiff CIVIL ACTION NO. 3:00CV835 (CFD)

V.

MOSTAFA REYAD AND WAFA REYAD Defendants DATE: JULY 3, 2007

DEFENDANT S MOTION FOR EXTENSION OF TIME Defendant Mostafa Reyad, hereby respectfully requests eleven days extension of time to submit his objection to the following Order of the Court and Plaintiff s motion: 1. The Court Order dated June 26, 2007 (Order # 504), Ordering WRITS of execution to Hudson United Bank and Bank of America, due July 16, 2007. Defendant s request extension of time to July 27, 2007, to allow attorney Josh Cohen, of the law firm of Day, Berry & Howard,a Connecticut law firm at Hartford, a reasonable time to prepare the exemption defense. Attorney Cohen is not and will not represent any of the Defendants. He was hired by AIG-VALIC the Insurance Company, in which Wafa Reyad has an exempted pension fund, and Mostafa Reyad is the beneficiary, the fund is not subject to attachment nor execution for creditors claims. Moreover Defendants has to serve other Insurance

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Case 3:00-cv-00835-CFD

Document 507

Filed 07/03/2007

Page 2 of 3

Companies throw the State of New Jersey Banking and Insurance Commissioner for other exemptions. Attorney Cohen has the assignment of AIG-VALIC just two(2) days ago. This extension will have no prejudice upon Plaintiff, and if it Denied by the Court it will cause substantial new damages to Defendants. 2. Plaintiff s motion for appointment of process server, entered on June 16, 2007, which the Court has Granted that motion and then entered on the docket, is due also on July 16, 2007. The Court Order and Plaintiff s motion are interwining should be extended together to July 27, 2007.

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Case 3:00-cv-00835-CFD

Document 507

Filed 07/03/2007

Page 3 of 3

The Defendant Mostafa Reyad

By: Mostafa Reyad 2077 Center Ave # 22D Fort Lee, NJ 07024 Home Phone. 201-621-3925 Day Phone. 203-325-4100 E-mail. [email protected]

CERTIFICATE OF SERVICE

The undersigned certifies that on July 3, 2007 has emailed this document to:

1. David R. Schaeffer, Esq. [email protected]

and delivered by hand a true copy of the same to Wafa Reyad

Mostafa Reyad

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