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

Case 2:90-cr-00018-AHN

Document 232

Filed 07/26/2006

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UNITED STATES DISTRICT COURT DISTRICT OF CONNECTICUT UNITED STATES OF AMERICA V. LOUIS PUGLIANO, GAETANO MILANO, FRANK PUGLIANO, and FRANK COLANTONI : : : : : : : : :

CRIMINAL NO. 2:90CR00018(AHN) CIVIL NOS. 3:95CV1171(AHN) 3:95CV1145(AHN) 3:95CV1330(AHN) 3:97CV409(AHN) July 26, 2006

GOVERNMENT'S MOTION FOR EXTENSION OF TIME The Government moves for an extension of time, nunc pro tunc, within which to respond to the petitioners' Motion for Rule 54(b) Judgment, which was filed on June 12, 2006. Since the time the original motion was filed, the parties have met concerning the parties' positions on the pending claims and expect to continue to discuss those positions. In view of those discussions, the Government respectfully requests and extension of time to respond to the petitioners' motion up to and including September 8, 2006. This is the first motion to extend this particular deadline. The Government has sought the petitioners' position on this motion but has been unable to determine the petitioners' position. WHEREFORE, the Government respectfully requests an extension of time up to and including September 8, 2006 within which to file its response to the petitioners' motion. Respectfully submitted, KEVIN J. O'CONNOR UNITED STATES ATTORNEY

______________________________________ JAMES K. FILAN, JR. ASSISTANT UNITED STATES ATTORNEY Federal Bar No. ct15565 915 Lafayette Boulevard, Room 309 Bridgeport, Connecticut 06604 (203) 696-3000

Case 2:90-cr-00018-AHN

Document 232

Filed 07/26/2006

Page 2 of 2

CERTIFICATION I hereby certify that a copy of the within and foregoing was mailed, postage prepaid, this 26th day of July, 2006, to: John M. Thompson, Esq. 1331 Main Street, Suite 320 Springfield, MA 01103 (Counsel for Louis Pugliano) Craig A. Raabe, Esq. 280 Trumbull Street Hartford, CT 06103 (Counsel for Gaetano Milano) Vincent Bongiorni, Esq. 95 State Street Springfield, MA 01103 (Counsel for Frank Pugliano) Michael Fitzpatrick, Esq. 10 Middle Street, 11th Floor Bridgeport, CT 06604 (Counsel for Frank Colantoni)

BY: JAMES K. FILAN, JR. ASSISTANT UNITED STATES ATTORNEY

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