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APPLICATION FOR EXTENSION OF TIME
TO FILE REPLY BRIEF
I, Kendrick Moxon, counsel for Petitioner Church of Scientology International,
hereby apply for an extension of time within which to file its Reply
Brief. Petitioner's
Reply Brief is presently due to be filed on January 27, 2005. Petitioner
requests its filing
date be extended 20 days, to and including February 16, 2005.
My predecessor counsel requested a previous extension for the Reply
Brief in
December and because I am new counsel, I require some additional time
to familiarize
myself with the substantial record in this matter, and to prepare the
Reply Brief.
Real party in interest has indicated his consent to a 20-day extension
of time.
1
I need and request an extension to file this brief because I am new counsel
in this
case, having been retained only this week to prepare the Reply memorandum
and to
conduct further proceedings herein.
I certify that I have delivered a copy of this application to my clients
pursuant to
California Rules of Court, Rule 45(f.)
I declare under the penalties of perjury of the laws of the State of
California that
the foregoing is true and correct. Signed this 24th day of January, 2005
in Los Angeles,
California.
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