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

Case 3:01-cv-02374-CFD

Document 121

Filed 07/07/2008

Page 1 of 2

UNITED STATES DISTRICT COURT DISTRICT OF CONNECTICUT

: : : v. : : TOWN OF STONINGTON, ET AL, : Defendants :

EDWARD BROWN, Plaintiff,

3:01-CV-02374 (CFD)

July 7, 2008

MOTION FOR AN EXTENSION OF TIME TO RESPONDE TO DEFEDNANTS MOTION FOR SUMMARY JUDGMENT

Plaintiff's appointed counsel respectfully requests that he be granted a nine day extension, to July 16, 2008, to respond to Defendants' Motion for Summary Judgment. As the Court is aware, one week ago plaintiff's counsel sought, and was granted, an extension of time to file plaintiff's response to defendants' motion for summary judgment. The response was due today. Unfortunately, despite their best efforts, plaintiff and counsel could not meet. In addition to the required discussion about the merits of the case, counsel is in need of materials in Mr. Brown's possession. Counsel was supposed to meet with Mr. Brown this afternoon. However, due to complications, Mr. Brown was unable to make the appointment. Counsel and Mr. Brown are scheduled to meet Wednesday, July 9, 2008, at 9:00 a.m. At such time counsel and Mr. Brown will discuss the merits of his claims, the defendants' motion for summary judgment, and the best way in which to proceed with this action. Counsel apologizes to the court and the defendants for the delay in this matter. Indeed, counsel spoke with counsel for the defendants, Attorney Beatrice S. Jordan, from Howd & Ludorf, regarding the case. After counsel apologized to her regarding this motion for an extension, she registered no objection

Case 3:01-cv-02374-CFD

Document 121

Filed 07/07/2008

Page 2 of 2

to this motion. Furthermore, a brief foray into settlement was had, which will be related to Mr. Brown for his consideration. Therefore, for the above stated reasons, it is respectfully requested that a nine day extension of time be granted for Plaintiff to file his response to Defendants' motion for summary judgment, until July 16, 2008.

RESPECTFULLY SUBMITTED, THE PLAINTIFF,

BY:

/s/ John F. Geida /s/ John F. Geida, Esq. Fed. Bar No. ct27468 The Law Offices of Norman A. Pattis, LLC 649 Amity Road, PO Box 280 Bethany, CT 06524 Tel. 203-393-3017 Fax. 203-393-9745

CERTIFICATION I hereby certify that on July 7, 2008, a copy of the foregoing MOTION FOR AN EXTENSION OF TIME was filed electronically. Notice of this filing will be sent by e-mail to all parties by operation of the Court's electronic filing system. Parties may access this filing through the Court's CM/ECF System.

/s/ John F. Geida /s/ John F. Geida Fed. Bar No. ct27468 Law Offices of Norman A. Pattis LLC 649 Amity Road, PO Box 280 Bethany, CT 06524 Tel: (203) 393-3017 Fax: (203) 393-9745