Free Motion for Extension of Time to File Response/Reply to Motion - District Court of Connecticut - Connecticut

Case 3:03-cv-01055-AVC Document 79 Filed 01/11/2006 Paget of 3
UNITED STATES DISTRICT COURT
DISTRICT OF CONNECTICUT
DOLORES FONSECA, RAFAEL FONSECA, : CRIMINAL ACTION NUMBER
AND MELANIE FONSECA, :
Plaintiffs, : 3:03cv01 055(AVC)
v.
JASON ALTERIO, JORGE LARREGUI,
AND THE CITY OF BRIDGEPORT :
Defendants : JANUARY 9, 2005
PLAINTlFFS’ SECOND REQUEST FOR EXTENSION OF TIME TO RESPOND TO
DEFENDANTS’ MOTION FOR SUMMARY JUDGMENT
The plaintiffs, DOLORES, RAFAEL AND MELANIE FONSECA, move this Court
to grant them a four-day extension of time up to and inciuding January 13, 2006 to
respond to the motions for summary judgment filed by all defendants in this case.
In support of this Motion, counsel for the plaintiffs represent as follows:
1. Defendant Jason Alterio filed a Motion for Summary Judgment and l
supporting documentation on or about November 8, 2005.
2. Defendant A|terio’s moving papers were not received by pIaintEffs’ counsel
until on or about November 15, 2005.
3. Defendants Larrequi and the City of Bridgeport also filed Motions for
Summary Judgment on or about November 10, 2005.
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Case 3:03-cv-01055-AVC Document 79 Filed 01/11/2006 Page 2 of 3
4. However, counsel for defendants Larregui and the City of Bridgeport
certified those defendants’ moving papers to plaintiff Dolores Fonseca
rather than to pIaintiffs’ undersigned counsel.
5. On or about December 5, 2005, plaintiffs’ counsel requested an extension
of time up to and including January 9, 2006, to respond to defendants’
Motion for Summary Judgment.
6. That Motion was granted, upon consent, on or about December 7, 2005.
7. F’laintiffs’ counsel has almost completed the response but needs several
days to finish their Memorandum of Law and Rule 56a(2) statement.
8. Counsel for the defendants, Elliot Spector, Esquire and Attorney Barbara
Brazzel—Massaro, have no objection to the requested extension of time.
l 9. This is the second request for extension of time in connection with the
pending motions for summary judgment.
10. There is good cause for granting this request.
11. No trial date has been set as of this time.

Case 3:03-cv-01055-AVC Document 79 Filed 01/11/2006 Page 3 of 3
THE PLAINTIFFS,
DOLORES FONSECA, RAFAEL FONSECA
A ELANIE FONSECA
BY:
ANE POLAN
Law Offices of Attorney Diane Polan, LLC
129 Church Street, Suite 802
New Haven, CT 06510
[email protected]
Telephone: 203-865-5000
Facsimile: 203-865-2177
Federal Bar No. ct00223
Their Attorney
CERTIFICATION
This is to certify that a copy of the foregoing has been sent via electronic mall,
this 9th day of January, 2006, to the following counsel and parties of record:
Attorney Barbara Brazzel-l\/Iassaro
Office of the City Attorney
999 Broad Street, 2““’ Floor
Bridgeport, CT 06604-4328
E-mail: [email protected]
Elliot B. Spector, Esquire
Noble, Spector, Young & O’Connor
One Congress Street, Fourth Floor
Hartford, CT 06114 __
E—malI: spector@ nsyo|aw.com E x .. ___..-·
DIANE POLAN
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