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

Case 3:03-cv-009 ‘ GIVI Document 20 Filed 05/1 004 Page 1 of 3
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UNITED STATES DISTRICT COURTE· , ·, i
DISTRICT OF CONNECTICUT _O O `. ,
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SANTLAGO E. CARTAGENA, A : CIVIL CASE No. 3i03'cv9‘28(J(iMj i
Plaintiff, : E A ;,;Ҥ_ l
THAMES VALLEY WATER Q E
BOTTLING co., INC. D/B/A ;
MANITOCK SPRINGS ;
Defendant. : MAY 18, 2004
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PLAINTIFF’S MOTION FOR EXTENSION OF TIME TO FILE PAPERS E
IN OPPOSITION TO DEFENDANT’S MOTION FOR SUMMARY i
JUDGMENT
The plaintiff respectfully moves that the court extend the time for the filing of the
plaintiff’ s papers in opposition to the defendant’s motion for summary judgment through June
26, 2004. Counsel for the plaintiff represents that he has been involved in various depositions
during the preceding 21 days, nine in all, not allowing him sufficient time to address the issues I
raised by the defendant in its motion for summary judgment. Counsel for plaintiff further U i
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represents that he has had to spend considerable preparing memorandums in two other matters
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Wherefore, the plaintiff requests that the court extend the time within which to tile his
opposition to the defendants’ motion for summary judgment to June 26, 2004.
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ase 3:03-cv-0O9@GM Document 20 Filed 05/@9004 Page 2 of 3
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The plaintiff’ s counsel has consulted with defendant’s counsel and he does not object to l
the Court’s granting the motion for a continuance.
The plaintiff has not tiled any prior motions for an extension of time in this matter.
THE PLAINTIFF — SAN TIAGO CARTAGENA
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BY ( L E S I { Q/m....—.r_
Thomas W. Bucci, for
WILLINGER, WILLINGER & BUCCI, P.C. (
855 Main Street l
Bridgeport, CT 06604 g
Tel: (203) 366-3939 }
Fax: (203) 337-4588
Fed. Bar #ct0'7805 l
Email: thomasbucci@ea1t11lin1<.net
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ase 3:03-cv-OOQQQIGIVI Document 20 Filed 05/1@%004 Page 3 of 3
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CERTIFICATION
I hereby certify that a copy of the foregoing Plaintiffs Motion for an Extension of Time
has been sent, by First Class Mail, postage prepaid, on this 18th day of May, 2004, to:
Richard J. Pascal, Esquire
O’BRIEN SHAFNER, STUART, KELLY
& MORRIS, P.C.
l38 Main Street
P.O. Box 310 a
Norwich, CT 06360
Tel: (860) 889-3855 j
Fax: (860) 886-6352
Fed. Bar # ct03 l5l
Q Somas W. Bucci
Willinger, Willinger & Bucci, P.C.
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