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

Case 3:03-cv-01003-AWT

Document 40

Filed 11/23/2004

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UNITED STATES DISTRICT COURT DISTRICT OF CONNECTICUT VALENTINE BUCKNOR, Plaintiff, v. C&S WHOLESALE GROCERS, INC., Defendant. : : : : : : : : :

CIVIL ACTION NO. 3:03-CV-01003 (AWT)

November 23, 2004

MOTION FOR EXTENSION OF TIME The defendant C&S Wholesale Grocers, Inc. moves for an extension of time of two (2) months, up to and including April 15, 2005, in which to file any dispositive motions. Defendant also moves for an extension of time of two (2) months, up to and including May 18, 2005, to file the joint trial memorandum, if no dispositive motions are filed. This is the defendant's second request for an extension of time with respect to the dispositive motion and joint trial memorandum deadline. On November 11, 2004, the Court granted a joint motion to extend the discovery and dispositive motion deadline to February 15, 2005. However, this creates a simultaneous discovery and dispositive motion deadline leaving defendant no time after the close of discovery to draft and file its dispositive motions. As a result, defendant seeks two months after the close of discovery on February 15, 2004 to draft and file its dispositive motions. The joint trial memorandum would

Case 3:03-cv-01003-AWT

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Filed 11/23/2004

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then be due approximately one month later, May 18, 2005. Plaintiff's counsel has been contacted regarding this Motion, and has no objection. DEFENDANT ­ C&S WHOLESALE GROCERS, INC.

By /s/ Scott E. Schaffer ­ ct25325 Murtha Cullina LLP CityPlace I ­ 185 Asylum Street Hartford, CT 06103 Its Attorneys Tel. No.: 860-240-6000 Fax No.: 860-240-6150 [email protected]

Case 3:03-cv-01003-AWT

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Filed 11/23/2004

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CERTIFICATE OF SERVICE I hereby certify that a copy of the foregoing was mailed first-class, postage prepaid, on this 23rd day of November 2004, to: Kenneth I. Friedman, Esq. Law Offices of Kenneth I. Friedman 2389 Main Street Glastonbury, CT 06033

/s/ Scott E. Schaffer ­ ct25325

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