Free Motion for Extension of Time - District Court of Connecticut - Connecticut

Case 3:00-cv-00662-CFD

Document 57

Filed 02/17/2004

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UNITED STATES DISTRICT COURT DISTRICT OF CONNECTICUT

ZORAIDA SANTIAGO Plaintiff v. DEPARTMENT OF SOCIAL SERVICES, ET AL. Defendants

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CIVIL ACTION NO. 3:00CV00662(CFD)

FEBRUARY 11, 2004

DEFENDANTS' MOTION TO MODIFY SCHEDULING ORDER COMES NOW the Defendants, Department of Social Services, Patricia Wilson-Coker and Dennis, King, and hereby respectfully request, pursuant to Local Rule 7, an enlargement of time of forty-five (45) days until March 27, 2004 to file a motion for summary judgment. The defendants, through counsel, represent the following: 1. 2. The parties are pursuing settlement negotiations. Defendants' counsel has another deadline of March 18 for a responsive pleading

in Fisher v. Helt and Doyle, 3:03CV02183 (RNC) and a deadline of April 15 for summary judgment in Lewis v. DOC, 3:02CV 2304 (MRK) among numerous other deadlines and obligations. 3. judgment. 4. 5. This is the defendants' fourth request to Modify the Scheduling Order. The undersigned left a message for Attorney Marc Glenn on Feb. 11, 2004, as to Further research on novel issues of law is required to prepare for summary

whether he has an objection to this requested extension, but has not heard back from him. The

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Case 3:00-cv-00662-CFD

Document 57

Filed 02/17/2004

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issue of filing a motion to modify had been discussed during the parties' telephone conference call with the court. WHEREFORE, the defendants respectfully request a modification of the Scheduling Order, resetting the deadline to file a motion for summary judgment for forty-five days (45) days from today until March 27, 2004. DEFENDANTS DEPARTMENT OF SOCIAL SERVICES, ET AL. RICHARD BLUMENTHAL ATTORNEY GENERAL

BY:

_____________________________ Beth Z. Margulies Assistant Attorney General 55 Elm Street, P.O. Box 120 Hartford, CT 06141-0120 Tel: (860) 808-5340 Fax: (860) 808-5383 [email protected] D. Conn. Federal Bar # 08469

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Case 3:00-cv-00662-CFD

Document 57

Filed 02/17/2004

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CERTIFICATION

I hereby certify that pursuant to Rule 5(b) of the Federal Rules of Civil Procedure a copy of the foregoing Defendants' Motion to Modify Scheduling Order was mailed, first class postage prepaid, this 13th day of February, 2004 to: Marc Glenn, Esq. Law Offices of W. Martyn Philpot, Jr. 409 Orange Avenue New Haven, CT 06511 Tel.: (203) 624-4666 Fax: (203 624-5050

______________________ Beth Z. Margulies Assistant Attorney General

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