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

. _ ·. ase 3:03-cv-OO41%§’CD Document 18 Filed O4/20/2004 Page 1 of 2 1
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UNITED STATES DISTRICT COU1R'I1: 1 1___1f 1] 1
DISTRICT OF CONNECTICLEER 1 $3 1
U.;$L {213 JYPF2 1 1:11:1511
ssc ; CASE NUMBlil1;R11i5:0§11Ci7’41i1§1€i’CD) 1
VS. ; 1
GLOBAL TELECOM SERVICES, LLC : APRIL 17, 2004 1
ET AL 1
MOTION FOR EXTENSION oE TIME RE: 1
DEFENDANT’S MEMORANDUM IN OPPOSITION TO
PLAINTIFF’S MOTION FOR SUMARY JUDGMENT T
The defendants, Global Telecom Services, LLC and Albert LaTouche, hereby move
this Honorable Court for a forty-five (45) day extension to May 17, 2004 in which to file a
memorandum in opposition to the plaintiff’s motion for summary judgment. In support of 1
this motion the defendants assert the following:
l. The p1aintiff’s filed a motion for Summary judgment on April l, 2004. The motion
and accompanying documents is approximately 5 inches thick. -
2. During the month of April, 2004, defense counsel was preparing for a murder trial
which was scheduled to begin jury selection on April 27, 20034. (State v Cartonio Mims,
Docket No. CR02-115260) However, on Thursday, April 15, 2004, the defendant in the
murder trial entered a guilty plea to a substituted charge which obviated the need for a trial.
3. Aside from the instant memorandum in opposition to lsummary judgment, defense 1
counsel has two other motions for summary judgment which he must respond to; the first is
due on April 19, 2004, and the other is due on May 3, 2004. `
4. Counsel for the defendant has notified the plaintiff concerning this request for an
extension and they raise no objection. - 1
Wherefore, the defendants move that this motion for extension of time be granted.
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. ` ase 3:03-cv-00415CD Document 18 Filed O4/2<(§OO4 Page 2 of 2 )
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Respectfullyl submitted, V
The Defend- nt
il,
By: I
* illiam _ . Paetzold
Moriarty, Paetzold & Babcock
140 Hebfon Avenue, Suite 102
Glastonbury, CT 06033 l
Tel No: Q860)657—l0l0 i
Federal Bar No.: ctl 0074 l
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CERTIFICATION I
THIS IS TO CERTIFY that a copy of the foregoing motion was mailed to the following A
counsel of record on this 17th day of April, 2004:
Jonathon J. Einhorn, Esq.
Attorney for Salvatore Cartelli
412 Orange Street
New Haven, CT 06511
SEC -
William Finkel, Esq. I, l
233 Broadway __ ll - I/Q
New York, NY 10279 / / /V i
Jr} l I l
· William H. l ' aetzold '
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