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IN RE WorldCOM

September 12, 2005.

In re WorldCom, Inc. Sec. Litig. Johnston
v.
Salomon Smith Barney, Inc. et al.



The opinion of the court was delivered by: DENISE COTE, District Judge

Dear Judge Cote:

This firm represents Mr. Perry Johnston in the above referenced matter. I have received various Motions to Dismiss from Defendants late in the afternoon on August 19, 2005. I understand that responses to the Motions are due today per the Court's Order of May 19, 2005 and that replies are due September 30, 2005. Unfortunately, I have been out of my office on other previously scheduled court matters in the time between August 19, 2005 and that has prevented me from being able to adequately respond to these motions. As such, I request that your honor allow me an additional ten days to respond with a corresponding ten days for Defendants to reply.

I thank you for your consideration of this request and enclose a formal motion in the event that is necessary. Should we need to do anything further or should you have any questions, please do not hesitate to contact me.

20050912

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