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

Case 3:03-cv-01017-JCH

Document 17

Filed 12/24/2003

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UNITED STATES DISTRICT COURT DISTRICT OF CONNECTICUT THE MEDIA GROUP, INC., NATIONAL COMMUNICATIONS CORPORATION, HOWE LABORATORIES, INC., AMERICAN DIRECT MARKETING, INC., AMERICAN FOUR, INTERNATIONAL MEDIA, INC., DURALUBE CORPORATION, INC., and HERMAN S. HOWARD, Plaintiffs, v. ARENT FOX KINTNER PLOTKIN & KAHN, PLLC and HUNTER CARTER, Esq., Defendants. : : : : : : : : : : : : : : : : Civil Action No. 3:03-CV-1017 (JCH)

DECEMBER 23, 2003

MOTION TO POSTPONE RULE 26(f) CONFERENCE AND REPORT

Defendant Arent Fox Kintner Plotkin & Kahn, PLLC ("Arent Fox"), hereby moves, through its undersigned counsel, for an order postponing the conference and report required by Fed. R. Civ. P. 26(f). Arent Fox has filed a motion to dismiss the Amended Complaint for lack of subject matter jurisdiction. The Rule 26(f) conference report was to have been submitted by December 16, 2003. The parties had been is discussions contemplating a withdrawal of this action. Those discussions have terminated.

Case 3:03-cv-01017-JCH

Document 17

Filed 12/24/2003

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Counsel for Arent Fox has inquired of counsel for plaintiffs and has been informed that plaintiffs consent to the relief requested herein. This is defendant Arent Fox's second request for an extension of the Rule 26(f) process. Therefore, Arent Fox respectfully requests that the Rule 26(f) conference be postponed, nunc pro tunc, until 30 days after the filing of Defendants' answer(s), should they be required, and that the parties jointly submit a form 26(f) report within 10 business days after the Rule 26(f) conference.

DEFENDANT ARENT FOX KINTNER PLOTKIN & KAHN, PLLC

By _______________________________ Michael G. Considine (ct 16023) Terence J. Gallagher (ct 22415) Day, Berry & Howard LLP One Canterbury Green Stamford, Connecticut 06901 tel. (203) 977-7300 fax. (203) 977-7301 E-mail: [email protected] Its Attorneys

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Case 3:03-cv-01017-JCH

Document 17

Filed 12/24/2003

Page 3 of 3

CERTIFICATE OF SERVICE

THIS IS TO CERTIFY that a copy of the foregoing was sent via first-class mail, postage pre-paid, this 23rd day of December, 2003 to:

Alexander H. Schwartz, Esq. 3695 Post Road, P.O. Box 701 Southport, Connecticut 06490

.

______________________________________ Terence J. Gallagher

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