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Page 1 UNITED STATES DISTRICT COURT, DISTRICT OF MASSACHUSETTS
In re
Docket No.: 04-12107-NG
DANH T. NGUYEN
A/k/a Lisa Le
BANKRUPTCY APPEAL
Debtor
MOTION FOR EXTENSION OF TIME TO FILE BRIEF
NOW COMES David G. Baker, attorney of record for the appellant in the above
captioned matter, and moves the Court for an extension of time to file the appellant’s brief, and
for reasons states due to an unexpected and unfortunate confluence of events, it has become
impossible for me to comply with the schedule set by the Order of October 4. Specifically, I
have two appeals for which briefs were due on October 19: this one and docket number 0412109-PBS. In addition, I was required to file briefs in two other appeals to the Bankruptcy
Appellate Panel after October 4 and before today. Finally, I have a trial in a divorce matter in
the Probate and Family Court (sitting in Springfield, MA) on October 20. The foregoing,
combined with routine matters, has made it impossible for me to prepare a brief which
adequately addresses the issues raised by this appeal.
Therefore, in order to avoid any prejudice to my client, I request an additional two weeks
to prepare and file a brief. I am unaware of any prejudice that the appellee would suffer if this
motion is granted.
WHEREFORE I request an extension of time to file the appellant’s brief, to November 2,
2004.
October 19, 2004
Respectfully submitted,
David G. Baker
David G. Baker
105 Union Wharf
Boston, MA 02109
(617) 367-4260
BBO# 634889
CERTIFICATE OF SERVICE
The undersigned hereby certifies that the within Motion was served upon the appellee by email
transmission of a true copy of the same to jbraunstein@riemerlaw.com
David G. Baker
David G. Baker, Esq.
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Case 1:04-cv-12107-NG
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Filed 10/19/2004
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UNITED STATES DISTRICT COURT, DISTRICT OF MASSACHUSETTS
In re
Docket No.: 04-12107-NG
DANH T. NGUYEN
A/k/a Lisa Le
BANKRUPTCY APPEAL
Debtor
MOTION FOR EXTENSION OF TIME TO FILE BRIEF
NOW COMES David G. Baker, attorney of record for the appellant in the above
captioned matter, and moves the Court for an extension of time to file the appellant’s brief, and
for reasons states due to an unexpected and unfortunate confluence of events, it has become
impossible for me to comply with the schedule set by the Order of October 4. Specifically, I
have two appeals for which briefs were due on October 19: this one and docket number 0412109-PBS. In addition, I was required to file briefs in two other appeals to the Bankruptcy
Appellate Panel after October 4 and before today. Finally, I have a trial in a divorce matter in
the Probate and Family Court (sitting in Springfield, MA) on October 20. The foregoing,
combined with routine matters, has made it impossible for me to prepare a brief which
adequately addresses the issues raised by this appeal.
Therefore, in order to avoid any prejudice to my client, I request an additional two weeks
to prepare and file a brief. I am unaware of any prejudice that the appellee would suffer if this
motion is granted.
WHEREFORE I request an extension of time to file the appellant’s brief, to November 2,
2004.
October 19, 2004
Respectfully submitted,
David G. Baker
David G. Baker
105 Union Wharf
Boston, MA 02109
(617) 367-4260
BBO# 634889
CERTIFICATE OF SERVICE
The undersigned hereby certifies that the within Motion was served upon the appellee by email
transmission of a true copy of the same to jbraunstein@riemerlaw.com
David G. Baker
David G. Baker, Esq.
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