I WI
I UNITED STATES DISTRICT COURT Im
I msrmcr or comuzcrrcor I I II -» ri
I IIIIII ~i A CI., I
I Plaintiff CIVIL ACTKINI I S I
I . 3.03CV00932 . . . _ _ _ I
I V. ; QQ I I - I — : _
I ATLAS FENCE COMPANY I
I D.B.A. ATLAS OUTDOORS : November 26, 2003 I
I Defendant
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PLAINTIFF’S MOTION FOR ENLARGMENT OF TIME TO RESPOND TO
I M. I
Pursuant to Fed. R. Civ. P. 6(b), the Plaintiff, Peter Sym, by and through his
I undersigned attorney, Eugene N. Axelrod ofthe Employment Law Group, LLC, hereby
respectfully requests that this Court allow Plaintiff a twenty-one (2l) day enlargement of
time, up to and including December 24, 2003 within which to file a Memorandum in I
Q Opposition to Defendant’s Motion to Dismiss, tiled September 29, 2003. In support
g theqzeof, Plaintiff represents as follows:
K _ ]_ I Plaintiff commenced this action on May 23, 2003. I
I I II TI 2. I Defendant tiled a Motion to Dismiss on September 29, 2003. I
I 3, II Ii I IIPlaintiff is inthe final stages of completing his Opposition to the Motion
. I II I II to Dismiss, and request a brief period of time in which to respond to the I
Defenda.nt’s Motion to Dismiss. I
I 4. The attomey assisting in the research and preparation of the Answer to the
I` I PII Motion to Dismiss for this case, Melissa Toddy, recently suffered the
5 death of her father, resulting in her having to immediately go to
E Pennsylvania to be with her family.
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