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

I . . Case 3:02-cv-O2192&WE Document 23 Filed O3/255004 Paget of 3
UNiri§?Ri£i§.?CD$i.L‘EEi.€8i’if DLE!) I
Zlillll MAH 22 P IZ 3."l I
.........................*..................................... X

Plaintiff : __ ._.i, . ,,,....,r, . , . - I
V. Z r I
BOARD OF EDUCATION FOR THE TOWN
OF GREENVIIICH :
Defendant I
----------——----————-—---------—--—-————--————----------------- X MARCH 19, 2004
MOTION FOR EXTENSION OF TIME {
In accordance with Rules 9(a) and 9(b) of the Local Rules of Civil Procedure, the
defendant Greenwich Board of Education (hereinafter "the Board") hereby moves for an
extension of time forthe filing of dispositive motions. The plaintiff intends to file a I
motion for summary judgment in this action. The defendant intends to file a cross I
motion for summary judgment as well on the defenses of lack ofjurisdiction/failure to
state a claim upon which relief may be granted. Counsel have intended to file the I
motions simultaneously. I
The current timeline for filing of dispositive motions is March 29, 2004 on I
extension. The undersigned counsel represented the Greenwich Board of Education in
the captioned case at a hearing before a hearing officer appointed by the State
Department of Education which is the subject of the current action in this court. Said
case involved seven (7) days of testimony and lengthy exhibits which must be reviewed
for a response to the Local 56(a)(1) Statement.
r





“ ` Case 3:02-cv-O2192(Y@WE Document 23 Filed O3/@@004 Page 2 of 3 I
Defendant’s counsel is `currently selecting a jury in the Stamford Superior Court I
in the case of Nicholas Stroumbakis, M.D. et al. vs. Town of Greenwich, D.N. CV 00 I
0181627S. Assuming jury selection is concluded promptly, the evidence in said case is I
not expected to conclude until the third week of April 2004 and may be extended
thereafter. The plaintiff in the state court case has disclosed the intention to call 20 I
witnesses and 96 documentary exhibits. The trial is as a result necessarily protracted.
Defendant’s counsel in this case has spoken to pIaintiff’s counsel and there is no
objection to the extension sought.
For the foregoing reasons, defendant respectfully requests the Court to grant an l
extension of time to I\/lay 31, 2004 for filing of dispositive motions.
I or;i=Ei~ioAi~1T I
GREENWICH BOAIQDQF EDUCATION I
Va rie E. Maze, I
Federal Bar No. CT 14080 I
Law Department, Town Hall I
101 Field Point Road,
Greenwich, CT 06836-2540 I
(203) 622-7877 {
Facsimile: (203) 622-3816 I
I
I
2 I



·· . . Case 3:02-cv-021924WWE Document 23 Filed 03/22/2004 Page 3 of 3
K.) tj
l
cERTu=icATioN oi= siznvlci-2
A copy of the foregoing has been mailed by first class mail, this 19th day of I
March 2004 to:
Attorney Lawrence W. Berliner I
Klebanoff & Phelan, P.C.
433 South Main Street, Suite 102
West Hartford, CT 06110.
_//'/mr-‘-rfa--`J I
A alerie E. Maze |

A l
l