[Ilaw] Sample Plaintiff Motion to extend time to file SJ Motion

Hi everyone hope everyone is having a nice tuesday so far. I am looking for anyone who has a sample Motion to extend time to file SJ Motions- grounds that other motions are pending that may or may not extend discovery so i need to know outcome of those motions before filing SJ Motion. Thank you. Sincerely, *Keetick L. Sanchez, Esq.* Attorney K L Sanchez Law Office, P.C. *Queens Office: *37-06 82nd Street Suite 304 Jackson Heights, New York 11372 *Long Island Office: *8 W. Merrick Road Sute 202 Freeport, New York 11520 646-701-7990 Fax: 646-837-5688 Follow KLS Law on Social Media: https://poplme.co/hash/CP3u4X9n/1/share