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

Case 3:03-cv-01015-DJS

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Filed 09/20/2004

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UNITED STATES DISTRICT COURT DISTRICT OF CONNCTICUT

GLENS FALLS INSURCE COMPANY:
a/s/o HAROLD and LAURN HEINZ Plaintiff
against

CIVIL ACTION NO. 303 CV 1015 (DJS)

COMMAND FORCE SECURTY
SYSTEMS, INC.

SEPTEMBER 20, 2004

Defendant

JOINT MOTION FOR ONE DAY EXTENSION OF TIME TO FILE OPPOSITION TO DEFENDANT'S MOTION FOR SUMMARY JUDGMENT, AND FOR DEFENDANT TO FILE REPLY TO SAID OPPOSITION
The plaintiff, Glens Falls Insurance Company, through counsel, moves for a one

day extension of time to September 21, 2004, by which to fie opposition to the
defendant's Motion for Summary Judgment fied August 30, 2004. The undersigned
counsel for the plaintiff represents as follows:
1.

Attorney Michael Mezzacappa, attorney for the defendant, consents to the

Court granting counsel for the plaintiff a one day extension of time to September 21,
2004, by which to fie an opposition to the defendant's Motion for Summary Judgment.
The plaintiff and the defendant also request that the deadline for the defendant to fie a

reply to the plaintiff s opposition to the Motion for Summary Judgment be extended by
one day.

2.

Counsel for the plaintiff requires a one day extension of time to fie an

opposition to the defendant's Motion for Summary Judgment because there are several
hundred pages of exhibits and transcripts which require reviewing and analyzing in order

to prepare the opposition. Due to the schedule of plaintiff s counsel during the past three

weeks, he is unable to complete the opposition by the deadline of September 20, 2004,

Case 3:03-cv-01015-DJS

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but he will do so by September 21, 2004. Accordingly, he needs a one-day extension of
time to fie the opposition.

WHREFORE, the plaintiff and the defendant, through their counsel, respectfully

request the Court to extend by one day the deadline for the plaintiff to fie an opposition
to the defendant's Motion for Summary Judgment, and for the defendant to fie a reply to
that opposition.

THE PLAITIFF,

GLENS FALLS INSURCE COMPANY a/s/o HAROLD and LAURN HEINZ

By Isl Joseph E. Mascaro
Joseph E. Mascaro, Esq. - CT 12736 Morrison Mahoney LLP
One Constitution Plaza, ioth Floor

Hartford, CT 06103 (860) 616-4441 (860) 541-4878
j mascaro(£morrisonmahoney. com

THE DEFENDANT COMMAND FORCE SECURTY SYSTEMS, INC.

Isl Michael Mezzacappa Michael Mezzacappa Kaufman Borgeest & Ryan LLP
99 Park Avenue

New York, New York 10016 212-980-9600
212-980-929 1 (facsimile)
mmezzacappa(£kbrny. com

Case 3:03-cv-01015-DJS

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Clerk's Offce United States District Court 450 Main Street Hartford, CT 06103