Free Motion for Leave to File Excess Pages - District Court of Connecticut - Connecticut

t _‘`· ; Case 3:00-cv-01124-WIG Document 141 Filed 11/28/2005 Page 1 of 3
J THE UNITED STATES DISTRICT COURT
·. DISTRICT O}? CONNECTICUT
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DENISE EVARTS, *
Plaintiff; *

v, Z CIV. ACTION NO. 3:OOCVll24CWIG)
TI-E SOUTHERN NEW *
ENGLAND TELEPHONE *
COMPANY, I
Defendant. * NOVEMBER 28, 2005
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Z DEFENBANTS MOTION T0 EXCEEI) PAGE LENGTK
f The defendant, the Southern New England Telephone Company (“SNET"), hereby
I respectfully requests permission to exceed the page limit set forth in the Federal Rules of Civil
Procedure for its Reply to Opposition to Motion for Summary Judgnent tiled on November 28, 2005.
an in support of this motion, SNIET states as follows:
The defendant seeks permission to Ble a Reply brief of 53 pages, including citations to the
evidence in the record. The additional pages are necessary in order to adequately respond to
" plaintiffs arguments, many of which are speculative and unsupported by the record. SNET has found
I it necessary to search through the record and identify for the Court why plaintiff s narrative arguments
do not reflect the evidence. To do this, SN]-ETl"'s Reply is lengthy in places in order to cite the record
evidence accurately.
l- GRAL ARGUBJENT IS NOTREQUEST ED

at Case 3:00-cv-01124-WIG Document 141 Filed 11/28/2005 Page 2 of 3
Z, In addition, plaintillf tiled a 38-page Opposition to Def`endan.t's Motion for Summary
lz Judgment, as well as an accompanying 65—page "Local Rule 56(a)(2) Statenaent"1 which she
purported to incorporate by reference in her Opposition. See Pl. Opp. at 4. In effect, plaintiff has
l` Sled 103 pages of argument (excluding exhibits) in opposition to SNET Motion for Summary
Judgment. Without the additional pages, SNET would be unable to set forth fully the relevant facts,
il supporting evidence, and case law in response to plaintiffs Opposition and in support of granting
summary judgment in this matter.
For the aforementioned reasons, the defendant respectfully requests permission of the Court
to tile a Reply to Opposition to Motion for Summary Judgnent not to exceed 53 pages.
° THE DEFENDANT,
SOUTHERN NEW ENGLAND TELEPHONE, l“NC.
ziéfj fg, l 5/, if
BYM,
i Lori B. Alexander
Federal Bar No. CT08970
Tyler Cooper & Alcorn, LLP
- 205 Church Street
‘ ` New Haven, Connecticut 06509
` Tel. (203) 78442200
Fax No. (203) 789-2133
E-Mail; elexander(g`ltylereooper.com
Z L The Statement does not comply the requirements ofthe Federal Rules and should not be
_ considered bythe Court.
Z: 2

if Case 3:00-cv-01124-WIG Document 141 Filed 11/28/2005 Page 3 of 3
if CERTIFICATE QF SERVTECE
i ._¤_ This is to certify that a copy ofthe foregoing was sent via first—c1ass mark, postage prepaid to
*. ali counsel and pm se parties of record on this 28*** day of November, 2005, as follows: Karen Lee
I Torre, Esquire, Law Offices ofKaren Lee Torre, 51 Elm Street, Suite 307 , New Haven, Connecticut
06510.
{E g 5
fl Lori”B. Aiexendet
-"‘- Federal Bar No. C'1“0S9'70