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

Case 1:04-cv-01372-JJF Document 31 Filed 11/14/2005 Page 1 of 3
IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF DELAWARE
In re: ) Chapter ll
AMERICAN METROCOMM I Bankruptcy No. 00-3358 (PJW)
CORPORATION, et al., )
Debtors, I
¥ii5M§§§Xi§`i§ZZ{iUr§f ``_“`````'-'``-`` ) I`I`I_``I_`_”`-----_-__`_---_----—__--
Appellant, I
v. ) Civil Action No. 04-1372 (JJF)
AMC UQUIDATING TRUSP i I I i
APr“·*r— i
4 __. ._ .. _ p
Plaintiff-appellant pro se Thomas Abrams, in accordance with Federal Rule
of Appellant Procedure 4(a)(5), respectfully requests an extension of time in which
to file his Notice of Appeal of the Order of this Honorable Court, signed October
ll, 2005 (which denied Plaintiff’s Motion for Reconsideration ofthe Court’s July
29, 2005 dismissing the above-captioned appeal with prejudice, for the
following reasons:
(l)The appellant was forced to evacuate his New Orleans residence due to
Hurricane Katrina; and appellant has re-located for the next several
months to Clearwater, Florida.
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Case 1:04-cv-01372-JJF Document 31 Filed 11/14/2005 Page 2 of 3
(2)Appellant has had to completely abandon his residence (half the roof
blew off), along with his computer and paperwork, including the files and
documents relating to the instant matter. Moreover, appellant has gone
through extreme difficulty evacuating and re-locating to another state, as
the result of Hurricane Katrina.
(3)Only recently has appellant obtained another computer, and his files
relating to this matter have recently been rescued from his severely-
damaged New Orleans residence and delivered to him.
WHEREFORE, for the foregoing reasons the plaintiff-appellant suggests
good cause and excusable neglect has been shown, in accordance with Federal
Rules of Appellant Procedure Rules 4(a)(5); and therefore an extension of time of
30 days is respectfully requested in which to file his Notice of Appeal.
Respectfully submitted,
EL-<\d-icq`,.
Thomas Abrams, appellant pro se
Certificate of Service
I hereby certify that a copy of
the foregoing pleading has been
mailed to all panics this ‘/ih day
or November, 2005.
ewiisraéhaw
Thomas Abrams
2

Case1:O4-cv-01372-JJF Document 31 Fi|ed11/14/2005 Page30f3
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