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

Case 3:01-cv-02374-CFD

Document 119

Filed 06/30/2008

Page 1 of 3

UNITED STATES DISTRICT COURT DISTRICT OF CONNECTICUT

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

EDWARD BROWN, Plaintiff,

3:01-CV-02374 (CFD)

June 30, 2008

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

Plaintiff respectfully requests that he be granted a one week extension, to July 7, 2008, to respond to Defendants' motion for summary judgment, for the following reasons: For the past three weeks Attorney John F. Geida was attempting to move his residence from one house to another. Unfortunately, there were major problems with the move, both the part of the buyers of Attorney Geida's house and on the part of the sellers of the house he planned to buy. The closing on the houses were delayed, not only causing Attorney Geida to suffer added expenses in the move, but his wife and children were forced to temporarily reside with a relative while Attorney Geida resided elsewhere. Furthermore, the problems became so severe that the closing on the house Attorney Geida planned to buy was canceled, after he sold his house, and he and his family were without a home for a period of time. Thankfully, the problems with the purchase were worked out, and Attorney Geida and his family moved into the new house this past weekend. Unfortunately, Attorney Geida was forced to deal with these issues and could not accomplish the tasks necessary for many of his cases, including the instant matter. This is the first request from Attorney Geida seeking an extension of time.

Case 3:01-cv-02374-CFD

Document 119

Filed 06/30/2008

Page 2 of 3

Additionally, Attorney Geida spoke with Attorney Beatrice S. Jordan, from Howd & Ludorf, representing the defendants, and she registered no objection to the request. Lastly, Attorney Geida contacted chambers prior to filing the instant motion, seeking guidance and clarification. Attorney Geida was willing to further discuss the matter should that have been necessary. Attorney Geida was instructed to file the motion promptly. Therefore, for the above stated reasons, it is respectfully requested that a one week extension of time be granted for Plaintiff to file his response to Defendants' motion for summary judgment, until July 7, 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

Case 3:01-cv-02374-CFD

Document 119

Filed 06/30/2008

Page 3 of 3

CERTIFICATION I hereby certify that on June 30, 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