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

Case 3:03-cv-00382-JCH

Document 31

Filed 10/29/2004

Page 1 of 2

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF CONNECTICUT ____________________________________x FRANKIE DELISE, : Petitioner : : v. : : KUMA DEBOO and KATHLEEN : HAWK-SAWYER, : Respondents. : ____________________________________x

CASE NUMBER 3:03 CV 382 (JCH)(HBF)

OCTOBER 27, 2004

PETITIONER'S MOTION FOR EXTENSION OF TIME The petitioner, FRANKIE DELISE, through counsel, respectfully requests that the deadline for filing her reply to respondents' Response to Amended Petition for Writ of Habeas Corpus be extended from October 29, 2004 to and including November 9, 2004 for the reason that petitioner has recently undergone tests that are relevant to her reply and the results of the tests have not yet been received. The date requested is 10 days in advance of the status conference with the Court that is scheduled for November 19, 2004. This is petitioner's first motion to extend the time within which to file her reply to respondents' Response to Amended Petition for Writ of Habeas Corpus. Counsel for the petitioner, Kathryn Emmett, has spoken with counsel for the respondent, A.U.S.A. Lauren M. Nash , concerning this request and is authorized to represent that respondents' counsel has no

Case 3:03-cv-00382-JCH

Document 31

Filed 10/29/2004

Page 2 of 2

objection to this request. Respectfully Submitted, The Petitioner,

By:_____________________________________________ KATHRYN EMMETT EMMETT & GLANDER 45 FRANKLIN STREET STAMFORD, CT 06901.13083 FEDERAL BAR NO. CT05605 (203) 324-7744 CERTIFICATION This is to certify that a copy of the foregoing has been mailed, postage prepaid, this 27th day of October, 2004, to: Lauren M. Nash, Esq. Assistant U.S. Attorney P.O. Box 1824 New Haven, CT 06508

__________________________________________ Kathryn Emmett