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

” Case 3:03-cv-00418-PCD Document 15 Filed O3/25/2004 Page 1 of 3

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UNITED STATES DISTRICT COURT . ` I-···· I
DISTRICT OF CONNECTICUT - ` t‘T'\ I
SECURITIES AND EXCHANGE COMMISSION, ·
Plaintiff, 3:03 CV 418 (PCD
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GLOBAL TELECOM SERVICES L.L.C. d/b/a : EXTEND DEADL E I
_ MEDICAL DISPOSAL DEVICES, : FOR FILING
ALBERT D. LATOUCHE and SALVATORE J. 1 MOTIONS
CARTELLI, JR., 1 I
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Defendants. 1
Pursuant to Local Civil Rule 7(b) and Judge Dorsey’s Supplemental Order for otion
Filing Procedure, Plaintiff Securities and Exchange Commission ("Commission”), res ctfully
requests, through its counsel, that the Court grant a 21-day extension, from April 23, 2 I until I
May 14, 2004, to for filing dispositive motions,
Pursuant to Local Rule 7(a)(l), this motion is not accompanied by a memorand I of law
because no disputed issue of law exists. The Commission requests an extension as foll ws: I
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l. This is the first request for an extension of time by the Commission.
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2. The Court entered the schedule agreed upon by the Commission, Defen nt pro se I
Salvatore J. Cartelli, Jr. ("Cartel1i") and attorney for Defendants Global Telecom Servi s, LLC I
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1, Case 3:03-cv-00418-PCD Document 15 Filed O3/25/2004 Page of 3 i
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d/b/a Medical Disposal Devices ("Medical Disposal") and Albert D. LaTouche ("LaTo che") in
their Form 26(f) Report of Parties Planning Meeting. I
3. The Court extended the deadlines of the Scheduling Order at Cartelli’s • unsel’s i
request after Cartelli retained counsel on or about October 9, 2003. The deadline for d lcovery
was extended to April 2, 2004 and the deadline for dispositive motions was extended ti April 23,
2004. g
4. The Commission has completed all discovery with the exception of obt ning an
affidavit from one witness, and the Commission expects to receive this prior to the dis very i
deadline. . {
5. The Commission needs additional time to file a motion for Summary Ju E gment to I
give adequate time for Commission to incorporate evidence into its supporting memor dum and Q
declaration to have sufficient time to submit a reply to memorandum after receiving an
opposing papers. _
6. Cotmsel for the Commission observes the Jewish Holiday on April 6-7 d April ~
12-13, and is unable to work those days.
7. Counsel for the Commission will be in London, England, between Apri 6-30,
2004, to take investigative testimony in a separate proceeding. l
S. Counsel for all Defendants have represented to the undersigned that the _ do not 1
obj ect to the Co1nmission’s request for this extension.
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E Case 3:03-cv-00418-PCD Document 15 Filed O3/25/2004 Page of 3 i
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WHEREFORE, Plaintiff requests a 21 —day extension to file dispositive motion
Dated: New York, New York ‘
March 24, 2004 I
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Respectfully submitted,
Ly ,., . ,,__ gf p I . td
WILLIAM EINKEL 1 I
Federal Bar Council N0. CT-24904 g
Attorney for Plaintiff i
SECURITIES AND EXCHANGE COM ISSION I
233 Broadway
New York, New York 10279 {
(646) 428-1716 g
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