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

Case 3:00-cv-01124-WIG

Document 152

Filed 01/17/2007

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UNITED STATES DISTRICT COURT DISTRICT OF CONNECTICUT DENISE EVARTS Plaintiff V. THE SOUTHERN NEW ENGLAND TELEPHONE COMPANY, Defendant : : : : : : : : :

Civil No. 3:00CV1124 (WIG)

JANUARY 12, 2007

MOTION FOR ENLARGEMENT OF TIME TO FILE JOINT TRIAL MEMORANDUM The undersigned counsel for the plaintiff respectfully moves this Court for an enlargement of time of two weeks to Tuesday, January 30, 2007 to submit the parties' Joint Trial Memorandum. Defense counsel has been contacted and has no objection to the granting of this motion. In support of this motion, the undersigned states that she is in the midst of researching and writing an appellate brief due to the Second Circuit Court of Appeals and researching and writing a reply brief to the Second Circuit in another appeal. These obligations are consuming all of the undersigned's time. The undersigned is unlikely to have an opportunity to turn her attention to the trial memorandum in this case until after the appellate briefs have been completed and submitted. Accordingly, plaintiff's counsel needs and respectfully requests an enlargement of time to January 30, 2007 to submit the joint trial memorandum in this case. The undersigned represents that there have been no previous extensions sought for this purpose.

Case 3:00-cv-01124-WIG

Document 152

Filed 01/17/2007

Page 2 of 2

Respectfully submitted: THE PLAINTIFF DENISE EVARTS

BY:________________________ KAREN LEE TORRE Federal Bar No. ct01707 Law Offices of Karen Lee Torre 51 Elm Street Suite 307 New Haven, CT 06510 (203) 865-5541 Her Attorney

CERTIFICATION I hereby certify that a copy of the foregoing was mailed, First Class, postage paid, on January 12, 2007, to: Lori Alexander, Esq. Tyler, Cooper & Alcorn 205 Church Street New Haven, CT 06509 ________________________________ Karen Lee Torre

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