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


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Date: November 17, 2003
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State: Connecticut
Category: District Court of Connecticut
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i Case 3:00-cv-OO97C~@HN Document 49 Filed 1 1/1 @03 Page 1 of 3
i ‘ H
` UNITED STATES DISTRICT COURT mn} NOV { ] I;) I2, I b I
y DISTRICT OF CONNECTICUT US UIS `!'l§i;{_r ;···l~; i
i BR il}iiilf`§—l _¤ IF ‘ i
‘ ’* · L.· _;
TIMOTHY HAYES : CIVIL ACTION NO: i
Plaintiff : 3:00CV0973(AHN)(HBF)
V. ; I
= l
COMPASS GROUP USA, INC., :
d/b/a EUREST DINING SERVICES :
and CARY ORLANDI : November 14, 2003
Defendants : {
PLAINTIFF’S MOTION FOR ENLARGEMENT OF TIME IN WHICH
TO RESPOND TO DEFENDANTS’ MOTION FOR SUMMARY JUDGMENT
Pursuant t0 Rule 6 of the Federal Rules of Procedure and Local Rule 9(b) the plaintiff in
the above—captioned matter respectfully moves for the initial extension of time of 30 days which I
may be granted by the clerk as provided for in Local Rule 9(b)(l), representing as follows: =
l) The plaintiff received a 220 page Motion for Summary Judgment from the Q
defendant on October 31, 2003. Q
2) Local Rule 9(b)(l) provides for 21 days within which to file required responses
l
to a motion for summary judgment. l
3) Previous professional and personal commitments of counsel for the plaintiff
precludes plaintiffs counsel from preparing and filing an appropriate response to the defendant’s `
Motion for Summary Judgment.


I Case 3:00-cv-0097wIN Document 49 Filed 11/1 @03 Page 2 of 3
I 4) The undersigned has inquired of Attorney Kenney as to the defendant’s
I position on this motion for extension of time and he has indicated he has no objection to this
I Motion. I
I 5) This is the iirst request for extension of time within which to respond to the
defendant’s Motion for Summary Judgment. I
6) Based on Local Rule 9(b)(l) and Federal Rule 6(e) the undersigned calculates E
the plaintiffs response to the defendant’s Motion for Summary Judgment, absent extension, is
due on November 21, 2003. I
Wherefore, the plaintiff respectfully requests an extension of time pursuant to
Local Rule 9(b)(l) to December 19, 2003.
E
PLAINTIFF I
TIMOTHY HAYES g
/ I
Stephen . c lene
His Attorn I
McEleney & cGra I
363 Main Stree I
Hartford, CT 06 · 6 I
Federal Bar No: ct040730
Telephone No: (860) 249-1400 I
Facsimile No: (860) 549-5865 l
E-mail: [email protected] I

N Case 3:00-cv-OO97@HN Document 49 Filed 11/1 @03 Page 3 of 3
Q
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i CERTIFICATION
I certify that a copy ofthe foregoing was sent via first class U.S. mail to the following 1
counsel of record this 14"‘ day of November, 2003:
Christopher A. Kenney 1
Sherin and Lodgen LLP =
100 Summer Stre.et
Boston, MA 02110
Margaret H. Paget, Esq.
Sherin and Lodgen LLP
100 Summer Street
Boston, MA 02110
Fred Frangie
Robert Fortgang & Associates
573 Hopmeadow Street ,
Simsbury, CT 06070 . `
Honorable Holly B. Fitzsimmons
United States District Court 1
915 Lafayette Boulevard ,» -*‘‘` A
Bridgeport, CT 06604 M
Stephen F.
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