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

Case 3:01-cv-01782-SRU

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Filed 11/17/2004

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UNITED STATES DISTRICT COURT DISTRICT OF CONNECTICUT ************************************ MARIA FIDELINA PEREZ * Petitioner * * v. * * IMMIGRATION & * NATURALIZATION SERVICE * and GARY COTE, * Officer-in-Charge, INS, * Respondents * * *************************************

CIV. NO. 3:01CV01782 (SRU)

November 17, 2004

JOINT MOTION TO ALLOW PETITIONER LEAVE TO FILE ADDITIONAL LEGAL MEMORANDUM OF LAW The Petitioner and the Respondent, by and through their undersigned counsel, hereby jointly move the Court for an extension of time, up to and including December 8, 2004, for the Petitioner to file additional legal memoranda in support of her Amended Writ of Habeas Corpus. The parties further move that the scheduling of the matter for argument and

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decision be made sometime thereafter at the Court's convenience.

RESPECTFULLY SUBMITTED THE PETITIONER MARIA FIDELINA PEREZ

BY: __________________________ JAMES E. SWAINE, Her Attorney The Law Offices of James E. Swaine
18 Trumbull Street New Haven, CT 06511

(203) 498-0086 Federal Bar: CT02793 RESPECTFULLY SUBMITTED, THE RESPONDENT IMMIGRATION & NATURALIZATION SERVICE KEVIN J. O'CONNOR UNITED STATES ATTORNEY

BY: __________________________ JAMES K. FILAN, JR. Assistant United States Attorney 915 Lafayette Blvd.
Bridgeport, CT 06604

(203) 696-3000 2

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Federal Bar: CT15565

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CERTIFICATION This is to certify that a copy of the foregoing was sent United States Mail, postage prepaid, on this date, to: James E. Swaine The Law Offices of James E. Swaine
18 Trumbull Street

New Haven, CT 06511 Dated at Bridgeport, Connecticut this 17th day of November, 2004.

JAMES K. FILAN, JR. ASSISTANT UNITED STATES ATTORNEY

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