11/10/09: Motion for extension of time to respond

I am the Defendant [redacted] and I hereby request an extension to answer the Complaint until 12/14/09 so that I have more time to look for an attorney to represent me.

I have to commute to NYC to work and due to my financial situation I cannot afford to take time off work. The stress has been causing medical problems including ocular rosacea. My eyes sting water and cloud up making it hard to read and write.

I was making payments to Federal Debt Relief System for several enrolled accounts including the Citibank account when it sued me. I then found Christine Baker’s websites about the FDRS scam and she contacted Cohen & Slamowitz on my behalf.

Unfortunately, Ms. Baker has not been able to speak with an attorney at Cohen & Slamowitz and her Declaration regarding her futile efforts to discuss my situation is attached along with her Exhibits.

Ms. Baker received the Affidavit of Service from Cohen & Slamowitz last Friday and it states that the summons and complaint were left at my door on 10/3/09, while in fact the papers were not left at my door until 10/10/09. The Affidavit of Service also states that the documents were mailed to me on 10/7/09, but I did not receive this mailing except for the summons to appear at the Poughkeepsie City Court.

I hereby respectfully request that the Court grant my request to give me until December 14, 2009 to retain an attorney to properly respond to the Complaint.

Respectfully submitted, 11/10/09.

________________________________

[redacted]
CERTIFICATE OF SERVICE

I mailed a copy of this motion and declaration and exhibits by first class mail on 11/10/09 to:

COHEN & SLAMOWITZ
ATTORNEYS FOR PLAINTIFF
P.O. BOX 9004,
CROSSWAYS PARK DR.
WOODBURY, NY 11797-9004

Dated this 10th day of November, 2009

_________________________
[redacted], Defendant pro per



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