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

_* Case 3:00-cv-00973-AHN Document 51 Filed 12/19/2003 Page 1 of 3 1
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UNITED STATES DISTRICT COURT
lllH}1l1ZlZ 13 /\11=03 4
DISTRICT OF CONNECTICUT _ 1
L.1QE»;·E..11,;. -
TIMOTHY HAYES : CIVIL ACTION NO:
Plaintiff : 3:00CV0973(AHN)(HBF) ·
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v. : 1
COMPASS GROUP USA, INC.,
d/b/:1 EUREST DINING SERVICES :
and CARY ORLANDI : December 19, 2003
Defendants :
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PLAIN'I`}§FF’S MOTION FOR ENLARGEMENT OF TIME IN WHICH I
T0 RESPOND T0 DEFENDANTS’ MOTION FQR SUMMARY JUDGMENT ‘
Pursuant to Rule 6 ofthe Federal Rules of Procedure and Local Rule 9(b) the plaintiff in
the above-captioned matter respectfully moves for the second extension of time of 14 days within
which to respond to the defendants' Motion for Summary Judgment, representing as follows:
1) The plaintiff received a 220 page Motion for Summary Judgment from the 1
defendant on October 31, 2003.
2) On November 14, 2003 the plaintiff filed his initial Motion for Extension of F
Time, for 30 days, which the clerk is empowered to grant, and did grant pursuant to Rule 9(b)( 1)
ofthe Local Rules of Civil Procedure. Therefore, this is the second request for extention.



· r Case 3:00-cv-00973-AHN Document 51 Filed 12/19/2003 Page 2 of 3
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3) Some ofthe documents disclosed by the defendants to the plaintiff were i
disclosed under Court-ordered seal and can only be viewed by the plaintiff, Timothy Hayes, upon
consent ofthe defendants. In reviewing the extensive documentation involved in this case in l
preparation for response to the Motion for Summary Judgment, plaintiffs counsel determined Mr. R
Hayes should review some ofthe documents in order to determine whether or not there is 1
information which should be included in the plaintiffs response. On December 2, 2003 plaintiffs
counsel faxed a request to defendants' counsel seeking authorization for Mr. Hayes to review i
specified documents. Plaintiffs counsel received the authorization for Mr. Hayes to review the I
documents on December 16, 2003, 14 days later. Given the impending holidays, it is difficult to 1
schedule a conference with the plaintiff] in plaintiffs counsel's office (as would be required), in
order to examine and consider the documents. For this reason, and the need to complete certain
portions ofthe response, plaintiff's counsel requests a 14-day additional extension within which to R
respond to the Motion for Summary Judgment. 1
4) On December 18, 2003 Attorney Christopher A. Kenney consented to the 14- I
day extension requested herein, on the condition the time within which the defendants have to
respond is extended to January 16, 2004. The plaintiff agrees with this condition.
5) A trial date has not been set.
Wherefore, the plaintiff respectiirlly requests an extension of time within which to
respond to the defendant's Motion for Summary Judgment to January 2, 2004, and an extension
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‘ Case 3:00-cv-00973-AHN Document 51 Filed 12/19/2003 Page 3 of 3 I
within which the defendant may reply, to January 16, 2004. l
PLAINTIFF J ,
TIMOTHY HAYES f" W
Stephe . Eleney
I-Iis Attom '
McEleney McGrai1
363 Mai Street
Hartford, CT 06106
. Federal Bar No: ct040730
Telephone No: (860) 249-1400 T
Facsimile No: (860) 549-5865 i
E—mai1: stephen@mceleneylaw. com
CERTIFICATION
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I certify that a copy of the foregoing was sent via first class U.S. mail to the following
counsel of record this 19"‘ day of December, 2003: I
Christopher A. Kenney, Margaret H. Paget, Esq.
Sherin and Lodgen LLP l
100 Summer Street
Boston, MA 02110
Fred Frangie i
Robert Fortgang & Associates '/
573 Hopmeadow Street =
Simsbury, CT 06070
Honorable Holly B, Fitzsimmons
United States District Court
915 Lafayette Boulevard t
Bridgeport, CT 06604
Stephen F. Vi E I
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