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

Case 3:03-cv-00712-WWE

Document 107

Filed 08/18/2005

Page 1 of 2

UNITED STATES DISTRICT COURT DISTRICT OF CONNECTICUT ____________________________________ GERTRUDE BAYONNE, Plaintiff, : : v. : Civ. Action No. 3:03CV0712(WWE)

PITNEY BOWES, INC., et al. : Defendants. ____________________________________:

August 17, 2005

PLAINTIFF'S MOTION FOR EXTENSION TO PAY COSTS AND FEES

Plaintiff, Gertrude Bayonne, files the instant motion requesting a two week extension from the Court's August 2, 2005 Order awarding costs and fees to Defendant Pitney Bowes, Inc. Plaintiff was ordered to pay such costs and fees by August 12, 2005. Plaintiff respectfully requests a two-week extension of time to pay such fees and costs to Defendant, up to and including August 24, 2005. The undersigned submits that good cause exists for granting the instant motion. The undersigned was away on vacation from August 2 to August 12, 2005, 2005, and unaware of the August 2, 2005 Court Order, delivered electronically through PACER. The undersigned contacted counsel for the Defendant on August 15, 2005, who consented to the instant motion. This is Plaintiff's first motion for extension of time. Plaintiff respectfully requests that the Court grant the instant motion. ORAL ARGUMENT NOT REQUESTED TESTIMONY NOT REQUIRED

Case 3:03-cv-00712-WWE

Document 107

Filed 08/18/2005

Page 2 of 2

GERTRUDE BAYONNE Plaintiff By:_____________________ Mark P. Carey(ct17828) Carey & Associates, P.C. 71 Old Post Road, Suite One Southport, CT 06890 (203) 255-4150 tel. (203) 255-0380 fax. [email protected] Her Attorney CERTIFICATE OF SERVICE THIS IS TO CERTIFY, that the foregoing was delivered via first class mail, postage prepaid, this the 17TH day of August, 2005 to: John G. Stretton Edwards & Angell, LLC Three Stamford Plaza 301 Tresser Boulevard Stamford, CT 06901 Attorney for Defendants Don Sullivan Morgan Lewis & Bockius, LLP One Market, Spear Street Tower San Francisco, CA 94105 Attorney for Defendants _______________________ Mark P. Carey