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

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Case 2:90-cr-00018-AHN Document 214 Filed 01/11/2006 Page 1 of 3
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UNITED STATES DISTRICT COURT i l A I l U A
FOR THE DISTRICT OF CONNECTICUT
)
GAETANO J. MILANO ) MASTER DOCKET NO.
) 2:90CR18(AHN) .
) r
v. )
)
UNITED STATES OF AMERICA ) JANUARY 11, 2006
Mi I
MOTION FOR ENLARGEMENT OF TIME ·
WITHIN WHICH TO FILE A REPLY MEMORANDUM
In accordance with Rule 7 of the Local Rules of Civil Procedure, the petitioner, Gaetano
Milano, hereby moves for an eight-day extension of time, mmc pro tune, up to an including
January 12, 2006, within which to file a Reply Memorandum In Support Of His Renewed Motion
for Leave to Conduct Discovery. In support of this Motion, Mr. Milano states the following:
l. In September of 2005, Mr. Milano filed a Renewed Motion for Leave to Conduct
Discovery in connection with his § 2255 petition.
2. After an extension of time, on December 16, 2005, the Govermnent served an
opposition memorandum.
3. Without an extension, Mr. Milano’s reply memorandum, if any, was due on
January 4, 2006.
4. Due to the holidays and the demands of other matters, undersigned cotmsel


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i · - Case 2:90—cr-OOO18eAHN Document 214 Filed O1/1_1_/2006 Page 2 of 3 {
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required additional time to complete a reply memorandum.
-5. The Government has no objection to this eight-day enlargement of time. ;
- 6. This is the first motion for enlargement of time on this issue. K
7. Mr. Milano has filed herewith the proposed Reply Memorandum in order to y
reduce delay in the event that the Court grants this eight—day enlargement of time mmc pro tunc.
WHEREFORE, Mr. Milano moves for an eight-day enlargement of time, mmc pro {unc,
within which to file a Reply Memorandum in support of his renewed Motion for Leave to }
Conduct Discovery.
PLAINTIFF, GAETANO J. MILANO '
By S R
Craig . Raabe
Federal Bar No. ct 041 16
RoBrNsoN & Cor-E LLP
280 Trumbull Street
Hartford, CT 06103
Telephone: (860) 275-8200
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" h l " Case 2:[email protected] Document 214 Filed O1/@462006 Page 3 of 3
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CERTIFICATE OF SERVICE
This is to certify that a copy of the foregoing was mailed, via first-class mail, postage
prepaid, on this 11th day of January, 2006, to the following counsel of record:
John M. Thompson, Esq. I Vincent Bongiorni, Esq. é
Thompson & Thompson PC 95 State Street l
1331 Main Street, Suite 320 Springfield, MA 01103
Springfield, MA 01103
Michael A. Fitzpatrick, Esq. I/ia Federal Express
Park City Plaza James K. Filan, Jr., Esq.
10 Middle Street, 11t Floor United States Attorneys Office .
Bridgeport, CT 06604 915 Lafayette Boulevard
Bridgeport, CT 06604
Craig A. aabe
E
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