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

Case 3:00-cv-00681-RNC

Document 121

Filed 04/22/2004

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UNITED STATES DISTRICT COURT DISTRICT OF CONNECTICUT

NORMA WATTS, In her Individual Capacity and as Administratrix of the Estate of AQUAN SALMON V. CITY OF HARTFORD; POLICE DEPARTMENT OF THE CITY OF HARTFORD; JOSEPH F. CROUGHWELL, Individually and in his Official Capacity as Chief of Police of the City of Hartford; OFFICER ROBERT C. ALLAN, Individually and in his Official Capacity as a Hartford Police Officer

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CIVIL ACTION NO. 3:00CV0681 (RNC)

APRIL 21, 2004

MOTION FOR ENLARGEMENT OF TIME Pursuant to Local Rule 7(b), the defendants move for an extension of time within which to file their Memorandum of Law in Opposition to the plaintiff's Motion for Reconsideration. Specifically, the defendants seek a fourteen (14) day extension of time, from May 5, 2004 to and including May 19, 2004. This is the defendants' first request for an extension of the deadline at issue. The plaintiff's counsel does not consent to the granting of this motion.

05645.0555

Case 3:00-cv-00681-RNC

Document 121

Filed 04/22/2004

Page 2 of 3

The defendants respectfully submit that good cause exists for the granting of their motion. In particular, additional time is needed to fully analyze the exhibits submitted, cases cited and arguments made in support of the plaintiff's Motion for Reconsideration. Moreover, the defendants' counsel have competing case obligations, including the preparation of a trial memorandum and preparation for a settlement conference in this case. Accordingly, despite the diligence of the defendants' counsel, the deadline at issue cannot reasonably be met. WHEREFORE, good cause having been show, the defendants respectfully request that the Court grant their motion and extend their time to file a Memorandum of Law in opposition to the plaintiff's Motion for Reconsideration, from May 5, 2004 to and including May 19, 2004. THE DEFENDANTS

By James J. Szerejko Fed. Bar #ct4326 Eric P. Daigle Fed. Bar #ct23486 HALLORAN & SAGE LLP One Goodwin Square 225 Asylum Street Hartford, CT 06103 Tel: (860) 522-6103 Email: [email protected]

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Case 3:00-cv-00681-RNC

Document 121

Filed 04/22/2004

Page 3 of 3

CERTIFICATION This is to certify that on this 21st day of April, 2004, I hereby mailed a copy of the foregoing, postage prepaid, to: Nicholas P. Cardwell, Esq. CARDWELL, CARDWELL & SMORAGIEWICZ 108 Oak Street Hartford, CT 06106 Joseph A. Moniz, Esq. MONIZ, COOPER & McCANN 100 Allyn Street Hartford, CT 06103

Eric P. Daigle
540331.1(HS-FP)

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