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

Case 3:01-cv-02376-CFD

Document 33

Filed 08/18/2004

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UNITED STATES DISTRICT COURT DISTRICT OF CONNECTICUT ALTON O. GRAY VS. STATE OF CONNECTICUT DEPARTMENT OF SOCIAL SERVICES Defendant. Plaintiff, : : : : : : : : CIVIL CASE NO. 3:01CV2376(CFD)

AUGUST 17, 2004

PLAINTIFF'S MOTION FOR FURTHER EXTENSION OF TIME TO FILE JOINT TRIAL MEMORANDUM The plaintiff respectfully moves the court for a further extension of the time for filing the Joint Trial Memorandum through December 1, 2005. Counsel for the plaintiff represents that in a recent communication with the plaintiff's wife plaintiff's counsel was informed that the plaintiff remains on active duty with the United States military in Iraq. Plaintiff is expected to remain in Iraq through April 1, 2005. Plaintiff's counsel has not been able to communicate with his client since February of 2004. Plaintiff's counsel would request the opportunity to directly discuss with the plaintiff his intentions regarding this action upon his return from Iraq. Wherefore, the plaintiff requests that the court extend the time within which to file the Joint Trial Memorandum to December 1, 2005.

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Case 3:01-cv-02376-CFD

Document 33

Filed 08/18/2004

Page 2 of 3

Defendant's counsel does not object to this motion. This is the third request for an extension of time to file the Joint Trial Memorandum. THE PLAINTIFF ­ ALTON O. GRAY

BY______________________________________ Thomas W. Bucci, for WILLINGER, WILLINGER & BUCCI, P.C. 855 Main Street Bridgeport, CT 06604 Tel: (203) 366-3939 FAX: (203) 337-4588 Email: [email protected] Fed. Bar #ct07805

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Case 3:01-cv-02376-CFD

Document 33

Filed 08/18/2004

Page 3 of 3

CERTIFICATION THIS IS TO CERTIFY that on the 17th day of August, 2004, the original foregoing Plaintiff's Motion for Further Extension of Time to File Joint Trial Memorandum was sent by first class mail to the following: Beth Z. Marguiles Assistant Attorney General 55 Elm Street P.O. Box 120 Hartford, CT 06141-0120 Tel: (860) 808-5340 Fax: (860) 808-5385 Fed. Bar #ct08469 e-mail: [email protected] ________________________________ Thomas W. Bucci Willinger, Willinger & Bucci, P.C.

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