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

Case 3:01-cv-02376-CFD

Document 29

Filed 05/28/2004

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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)

MAY 27, 2004

PLAINTIFF'S MOTION FOR FURTHER EXTENSION OF TIME TO FILE JOINT TRIAL MEMORANDUM The plaintiff respectfully moves that the court extend the time for filing the Joint Trial Memorandum through May 1, 2005. Counsel for the plaintiff represents that in a recent

communication with the plaintiff's wife, after unsuccessful attempts to communicate with the plaintiff, plaintiff's counsel was informed that the plaintiff is presently on active duty with the United States military in Iraq. Plaintiff is expected to remain in Iraq through April 1, 2005. In discussions with the plaintiff's wife, the plaintiff's counsel was informed that the plaintiff was considering withdrawing this matter. However, the plaintiff's frame of mind may be colored by his present military assignment. Plaintiff's counsel would request the opportunity to directly discuss with the plaintiff his intentions upon his return from Iraq.

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Case 3:01-cv-02376-CFD

Document 29

Filed 05/28/2004

Page 2 of 3

Wherefore, the plaintiff requests that the court extend the time within which to file the Joint Trial Memorandum to May 1, 2005. Defendant's counsel does not object to this motion. This is the second 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 29

Filed 05/28/2004

Page 3 of 3

CERTIFICATION THIS IS TO CERTIFY that on the 27th day of May, 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 ________________________________ Thomas W. Bucci Willinger, Willinger & Bucci, P.C.

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