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

Case 3:03-cv-01003-AWT

Document 22

Filed 03/29/2004

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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)

MARCH 26, 2004

MOTION FOR EXTENSION OF TIME The defendant, C&S Wholesale Grocers, Inc. ("C&S") moves for an extension of time of thirty (30) days, up to and including April 25, 2004, in which to answer or otherwise plead in this employment discrimination action. This is C&S' second motion for extension of time in this matter, but its first request for an extension of time with respect to the recently amended complaint. C&S requests this extension because the Amended Complaint includes additional allegations that were not asserted in Plaintiff's pro se complaint. Accordingly, C&S' counsel requires additional time to investigate the additional allegations of the Amended Complaint. C&S' counsel has attempted to contact Plaintiff's counsel to obtain his consent to this motion, but has been unsuccessful.

NO ORAL ARGUMENT REQUESTED NO TESTIMONY REQUIRED

Case 3:03-cv-01003-AWT

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Filed 03/29/2004

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DEFENDANT - C&S WHOLESALE GROCERS, INC.

By______/s/ Derek T. Werner_____________________ Lissa J. Paris ­ ct04251 Derek T. Werner ­ ct23419 Murtha Cullina LLP CityPlace I - 185 Asylum Street Hartford, Connecticut 06103-3469 Telephone: (860) 240-6000 Facsimile: (860) 240-6150 Email: [email protected] [email protected] Their Attorneys

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Case 3:03-cv-01003-AWT

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Filed 03/29/2004

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CERTIFICATE OF SERVICE I hereby certify that a copy of the foregoing Motion for Extension of Time was mailed first-class, postage prepaid, on this 26th day of March, 2004 to: Kenneth I. Friedman, Esq. 2839 Main Street Glastonbury, Connecticut 06033

/s/s Derek T. Werner Derek T. Werner ­ ct23419