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

Case 3:00-cv-01059-DJS

Document 102

Filed 12/02/2003

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UNITED STATES DISTRICT COURT DISTRICT OF CONNECTICUT RICHARD B. SMITH, Plaintiff, v. THE GILLETTE COMPANY, Defendant. : : : : : : : : CIVIL ACTION NO. 3:00CV1059 (DJS)

DECEMBER 2, 2003

DEFENDANT'S MOTION ON CONSENT FOR AN EXTENSION OF TIME TO RESPOND TO PLAINTIFF'S MOTION TO ENFORCE SETTLEMENT AGREEMENT Pursuant to Local Rule 9(b), Defendant, The Gillette Company (hereinafter referred to as "Defendant"), respectfully moves for an extension of time in which to respond to Plaintiff's Motion to Enforce Settlement Agreement. Specifically, Defendant, with the consent of Plaintiff's counsel, requests an extension of time of two days, up to and including December 5, 2003. In support of this motion, Defendant states as follows: 1. The parties in this matter have been involved in ongoing discussions regarding the

resolution of this case. ORAL ARGUMENT NOT REQUESTED TESTIMONY NOT REQUIRED

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Case 3:00-cv-01059-DJS

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2.

On October 23, 2003, this matter was referred to Magistrate Judge Smith in an

effort to resolve the remaining settlement terms that are in dispute between the parties. 3. 4. 5. On October 29, 2003, Plaintiff filed a Motion to Enforce Settlement Agreement. Defendant's opposition is currently due on December 3, 2003. This extension of time is necessary to enable the Defendant's counsel to fully and

completely reply to Plaintiff's motion, and to give the parties and Magistrate Judge Smith an opportunity to resolve the remaining settlement terms that are in dispute between the parties. 6. Counsel for Defendant, Sarah Moore Fass, has discussed this motion for an

extension of time with Plaintiff's counsel, Stephen P. Horner. Attorney Horner consents to the granting of this motion for extension of time. 7. This is Defendant's second motion for an extension of time to file an opposition to

Plaintiff's Motion to Enforce Settlement Agreement.

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WHEREFORE, based on the foregoing, Defendant, with the consent of Plaintiff, respectfully requests that this Court grant Defendant a two day extension of time to reply to Plaintiff's Motion to Enforce Settlement Agreement, up to and including December 5, 2003.

DEFENDANT, THE GILLETTE COMPANY,

By ____________________________________ Albert Zakarian (ct 04201) Sarah Moore Fass (ct 18313) Day, Berry & Howard LLP CityPlace I Hartford, Connecticut 06103-3499 (860) 275-0100 (Telephone) (860) 275- 0343 (Facsimile) Its Attorneys

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Case 3:00-cv-01059-DJS

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CERTIFICATION THIS IS TO CERTIFY that a copy of the foregoing was mailed this 2nd day of December, 2003, via facsimile and first class mail, postage prepaid, to: Stephen P. Horner, Esq. Law Offices of Stephen P. Horner 2183 Post Road Darien, CT 06820-5604

______________________________________ Albert Zakarian

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