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

Case 3:00-cv—01124-WIG Document 137 Filed 11/14/2005 Page 1 of 3
THE UNITED STATES DISTRICT COURT
DISTRICT OF CONNECTICUT
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DENTSE EVARTS, *
I- *
ptitniatt *
Z.- *
v. * CIV. ACTION NO. 3:00CVl124W\/TG}
2):
'ITE SOUTHERN NEW *
it ENGLAND TELEPHONE *
F COIVIPANY, *
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‘:. Befendant. * NOVEMBER 14, 2005
.‘:’_ esesesssssieesseeease it
fl DEFENEANT S MOTION FOR EXTENS}ON OF TBVIE
Q-;. The defendant, the Southern New England Telephone Company, hereby requests an additional
I extension oftime of four days, through and including November I8, 2005, in order to {ile its reply
to plaintiits opposition to motion for summary judgment. The reason for the requested extension is
that defense counsel has been attending to a medical situation over the past week that has led to
if unexpected missed time from work that has made it impossible to tile the reply on this date. in
addition, in support ofthis motion, SNET states that plaiittiffs opposition brief included a 37-page
memorandum of law and 452 pages of exhibits, and that plaintiff requested and was granted several
I <:onsented—·to extensions of time for a total of three months (91 days) to prepare and tile her
?j' opposition to summary judgment, which was tiled September 20, 2005.
ORAL ARGUMENT IS NOT REQUESTE1)

`I Case 3:00-cv-01124-WIG Document 137 Filed 11/14/2005 Page 2 of 3
The umfersigned has attempted to contact plaintiffs counsel, Karen Torre but has been unable
to ascertain her position en this motion.
Dated at New Haven, Connecticut this 14th day of November, 2005.
TIE DEFENDANT,
SOUTHERN NEW ENGLAND TELEPHONE
af COMPANY
By yet gte:
Lori B. Alexzm er
Federal Bax No. CT 08970
g-Q TYLER COOPER & ALCORN, LLP
205 Church Street
P. O. Box l936
I New Haven, Connecticut 065094910
__'. Tel. (203) 784-S200
Fax (203) 789—2133
if; E-Mail; a1e>cander{@_ty1erc0oger.com
` j 2

gi. Case 3:00-cv-01124-WIG Document 137 Filed 11/14/2005 Page 3 of 3
CERTIFICATE OF SERVICE
This is to certify that a copy of the foregoing was mailed by Hrsbclass mail, postage prepaid
to ai} counsel and pro se panics of record on this i4”* day of November, 2005, as foliowsr Karon
Torre, Esquire, Law Gffxccs ofliaren Loc Torre, 51 Elm Street, Suite 307, New Haven, Connecticut
t 06510.
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E ix, > , gf? {E ,.»®
?_ Lori B. Alexander
`j Fedcrai Bar No. C'?08970
3