Free Motion for Hearing - District Court of Connecticut - Connecticut

Case 3:00-cv-01124-WIG

Document 144

Filed 06/07/2006

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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)

June 5, 2006

MOTION FOR ORAL ARGUMENT The undersigned counsel for the plaintiff, Denise Evarts, hereby respectfully moves this Court to hear oral argument on the matter of defendant's Motion for Summary Judgment. Good cause for this motion and for permitting oral argument is based upon the following: 1) The parties' submissions are voluminous. 2) Defense counsel sought and received permission to file an oversized reply brief. Local Rule limits reply briefs not only to 10 pages but the content of such reply briefs is usually limited to responding to those issues and arguments raised by the opposition brief. In this case, defense counsel filed a voluminous reply brief way beyond the page limit and which was also used for the purpose of introducing new evidence into the court record, evidence which was not included in defendant's original moving papers and which was also never disclosed to plaintiff's counsel during discovery. For the above reasons, the undersigned wishes to present oral argument to the court in order that the plaintiff be given fair opportunity to address defendant's oversized reply brief and its

Case 3:00-cv-01124-WIG

Document 144

Filed 06/07/2006

Page 2 of 3

introduction of new and not previously disclosed evidence into the court record.

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

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Case 3:00-cv-01124-WIG

Document 144

Filed 06/07/2006

Page 3 of 3

CERTIFICATION I hereby certify that a copy of the foregoing was mailed, First Class, postage paid, on June 5, 2006, to: Lori Alexander, Esq. Tyler, Cooper & Alcorn 205 Church Street New Haven, CT 06509

________________________________ Karen Lee Torre

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