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

Case 3:01-cv-02374-CFD

Document 113

Filed 02/25/2008

Page 1 of 3

UNITED STATES DISTRICT COURT DISTRICT OF CONNECTICUT

EDWARD BROWN vs. TOWN OF STONINGTON, ET AL

: : : : :

3:01cv2374 (CFD)

February 21, 2008

PLAINTIFF'S SECOND MOTION FOR EXTENSION OF TIME TO RESPOND TO SUPPLEMENT DEFENDANTS' MOTION FOR SUMMARY JUDGMENT The plaintiff, Edward Brown, respectfully requests an extension of time of thirty (30) days, up to and including March 23, 2008, within which to supplement his response to the motion of summary judgment tendered on him by the defendants. In

support of this motion, the undersigned represents as follows; 1. I am the lawyer for Edward Brown, the plaintiff in

this action. 2. The Court appointed me Pro Bono counsel for the

plaintiff on December 17, 2007. My appearance in this matter was filed on January 3, 2008. 3. On January 8, 2008, the Court reinstated the

defendants' motion for summary judgment. Plaintiff had until January 23, 2008, to supplement his response to the defendants' motion for summary judgment. 4. I am in the process of reviewing the file, and

drafting the plaintiff's supplemental response to the motion for summary judgment.

Case 3:01-cv-02374-CFD

Document 113

Filed 02/25/2008

Page 2 of 3

5.

I have been on trial in the Waterbury Judicial

District, on the case Rabia Ali v. Diane Polan, UWY-X10-cv-034010591-s. I have also just completed an Appellate Court brief in a murder case entitled, State of Connecticut v. Gregg Madigosky, A.C. 27689. For these reasons, the undersigned has been unable to complete the plaintiff's supplemental response to the defendants' motion for summary judgment. 6. I contacted my adversary, Attorney Beatrice S. Jordan,

to ascertain her position on this motion. Attorney Jordan consents to the granting of this motion.

WHEREFORE, I am requesting an extension of time of thirty (30) days up to and including March 23, 2008, in which to file the plaintiff's supplemental response to the defendants' motion for summary judgment.

BY:___/s/_________________________ Norman A. Pattis, Esquire Fed Bar No. Ct13120 Law Offices of Norman A. Pattis 649 Amity Road, P.O. Box 280 Bethany, CT 06524 Tel No. 203.393.3017 Fax No. 203.393.9745

Case 3:01-cv-02374-CFD

Document 113

Filed 02/25/2008

Page 3 of 3

CERTIFICATION This is to certify that a copy of the foregoing, Appearance, was mailed using U.S. Mail, this 21st day of February 2008, to the following counsel of record: Attorney Beatrice S. Jordan Howd & Ludorf 65 Wethersfield Avenue Hartford, CT 06114 By:______________________ /s/ NORMAN A. PATTIS Law Offices of Norman A. Pattis