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UNITED STATES DISTRICT COURT i. ll T ._
DISTRICT OF CONNECTICUT Fm.: I I., I.,) W: S R
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PETER SYM CIVIL ACTION CASE NO. J L I
: 303 CV 00932 (SRU) 5
Plaintiff, :
V. November 17, 2003 l
ATLAS FENCE COMPANY
D.B.A. ATLAS OUTDOOR. {
Defendant.
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PLAINTIFF’S MOTION FOR ENLARGEMENT OF TIME TO RESPOND TO i
DEFENDANTS MOTION TO DISMISS, FILED SEPTEMBER 29, 2003 l
Pursuant to Fed. R. Civ. P. 6(b), the Plaintiff} Peter Sym, by and through his undersigned i
attorney, Eugene N. Axelrod of The Employment Law Group, LLC, hereby respectfully requests I
that this Court allow Plaintiff a fourteen (14) day enlargement of time, up to and including
December 3, 2003, within which to file a Memorandum in Opposition to Defendant’s Motion to .
Dismiss, filed September 29, 2003. In support thereof] Plaintiff represents as follows:
1. Plaintiff commenced this action on May 23, 2003.
2. Defendant filed a Motion to Dismiss on September 29, 2003. i
3. Plaintiff is in the final stages of completing his Opposition to the Motion to
Dismiss, and requests a brief period of time in which to respond to the
Defendant’s Motion to Dismiss.
4. Plaintiff does not believe that this request will unduly hinder the administration of
this case. I
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Case 3:03-cv-OO9®RU Document 15 Filed 11/1 @03 Page 2 of 3
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5. Pursuant to Rule 9(b)(2) of the Local Rules of Civil Procedure, counsel for
Plaintiff has inquired of counsel for Defendant, who has not responded as to
whether or not he is in agreement to this request.
6. This is the second request for an enlargement of time with respect to this matter.
The Plaintifi
Peter Sym
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By l
Eugene N. Axelrod (CT00309) l
The Employment Law Group, LLC
8 Lunar Drive l
Woodbridge, CT 06525 y
(203) 389-6526
(203) 389-2656
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Case 3:03-cv-OO9@RU Document 15 Filed 11/18#§)O3 Page 3 of 3
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CERTIFICATION N
This is to certify that a copy of the foregoing was sent this date via iirst class mail, ,
postage prepaid to:
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Michael P. Devlin, Esq. {
Thomas A. Carroll, Esq.
Berchem, Moses & Devlin, P.C. I
75 Broad Street
Milford, CT 06460
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I I rt I ·>
Date elissa To dy _
Commissioner ofthe Supe r Court
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