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

I Case 3:03-cv-00571-SRU Document 25 Filed O1/22/2004 Page 1 of 2
I UNITED STATES DISTRICT COURT
I DISTRICT OF CONNECTICUT
I (Bridgeport)
JANE DOE, JR. ; I
ppa JANE DOE, SR., : Case No. 3:03 CV 571 (SRU)
1 3:01 CV 2298 (SRU) ;
Z I
V. :
CITY OF WATERBURY, ET AL January ZL, 2004
PLAINTIFF’S MOTION FOR EXTENSION OF TIME . I
The plaintiff herein, by and through the undersigned, moves that the deadline for her to I
tile her memorandum in rebuttal to that of the proposed intervener be extended four business
days until Monday, February 2, 2004. The proposed intervener was supposed to have tiled its
memorandum on or before Monday, January 12, 2004. However, co-counsel, Atty. Gerald L.
Harmon, did not receive his copy ofthe proposed intervener’s January 16, 2004 memorandum I
until Saturday, January 17, 2004. Further, the undersigned has yet to receive his copy irom
the proposed intervener as of this writing. The plainti;lf’s deadline for rebuttal memorandum I
was to be Monday, January 26*, 2004. Additional time is needed to compensate for the
proposed intervener not meeting its deadline. I
The undersigned has notified all ofthe offices of the counsel of record of this motion
but as of this time, the undersigned has not heard from other counsel with respect to their
opinions. This is the p1aintift"s first such request with respect to this memorandum.
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__ Case 3:03-cv-00571-SRU Document 25 Filed O1/22/2004 Page 2 of 2
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RESPECTFULLY SUBMITTED,
T
JANE Doa 11 T
*1*1-112 1> ty n F , T
W I U i T
BY: ___ A __ · · ‘ I T
· TY. ERSKINE D. T c I TOSH
FEDERAL BAR N0 c 9743
THE LAW OFFIC T S OF ERSKINE D. McINTOSH, P.C. T
3129 WHITNEY AVENUE, SECOND FLOOR T
HAMDEN, CONN. 06518-2364
(203) 787-9994
(203) 848-1213 Fax
COUNSEL FOR THE PLAINTIFF
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CERTIFICATION
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This is to certify that the foregoing was sent on this 22; th day of January, 2004 to: T
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Atty. Gerald L. Harmon T
290 Pratt Street .
Meriden, Conn. 06450
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Atty. Michael S. Hillis
Dobrowski, Knapsaek & Hillis, LLC T
205 Whitney Avenue T
New Haven, Conn. 06511
Atty. Michael W. Mackniaek
87 Madon Street T
Naugatuck, CT 06770 T
T
Atty. Elliot Spector
Sack, Spector & Karsten
836 Farmington Avenue
West Hartford, Conn. 06119-1544 T
Atty. Susan T. Pearlman
Asst. Attorney General
Office of the Attorney General (
110 Sherman Street / __ ..f.... - I T
Hartford, Conn. 06105 . l z T
'?' Y.1•:Rsr< D. c osn _ T
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