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

Case 3:00-cv-00662-CFD

Document 60

Filed 03/26/2004

Page 1 of 3

UNITED STATES DISTRICT COURT DISTRICT OF CONNECTICUT

ZORAIDA SANTIAGO Plaintiff v. DEPARTMENT OF SOCIAL SERVICES, ET AL. Defendants

: : : : : : :

CIVIL ACTION NO. 3:00CV00662(CFD)

March 26, 2004

DEFENDANTS' MOTION FOR EXTENSION OF TIME TO FILE SUMMARY JUDGMENT COMES NOW the Defendants, Department of Social Services, Patricia Wilson-Coker and Dennis King, and hereby respectfully request, pursuant to Local Rule 7, an enlargement of time of thirty (30) days to file their summary judgment motion, up to and including April 30, 2004. In support of their motion, the defendants represent as follows: 1. The current Scheduling Order has set the deadline for filing dispositive motions

on March 27, 2004. Inasmuch as said date is a Saturday, defendant's motion for summary judgment according to the rules of the court is due on Monday, March 29, 2004. 2. The parties are currently interested in settlement discussions. The parties are

scheduled for a settlement conference before a para-judicial officer, Attorney Emanuel Psarakis, on April 5, 2004. 3. The undersigned has been diligently working on the preparation of said summary

judgment motion and all accompanying paperwork. However, since the complaint alleges five counts: Title VII, 42 U.S.C. § 1983, negligent infliction of emotional distress, intentional infliction of emotional distress and negligent supervision, approximately a half a dozen affidavits must be prepared along with numerous documents. Furthermore, extensive legal arguments must

1

Case 3:00-cv-00662-CFD

Document 60

Filed 03/26/2004

Page 2 of 3

be written. As a result, defendants need more time to provide a comprehensive and adequate defense. 4. The undersigned has a heavy caseload and is also currently scheduled for

depositions on March 31, 2004, April 1, 2004, April 6, 2004 and April 12, 2004 in the matter of Lewis v. Department of Correction, 3:02CV2304(MRK). The discovery deadline is April 15, 2004 in that matter. 5. Pursuant to Local Rule 7(b), the undersigned contacted the office of plaintiff's

counsel, Marc Glenn, Esq., and left a message but as of this mailing has not received a response and therefore was unable to ascertain his position as to this motion.

WHEREFORE, the defendants respectfully request a modification of the Scheduling Order, extending the deadline for the filing of dispositive motions to and including April 30, 2004.

DEFENDANTS DEPARTMENT OF SOCIAL SERVICES, ET AL. RICHARD BLUMENTHAL ATTORNEY GENERAL

BY:

_____________________________ Beth Z. Margulies Assistant Attorney General 55 Elm Street, P.O. Box 120 Hartford, CT 06141-0120 Tel: (860) 808-5340 Fax: (860) 808-5383 [email protected] D. Conn. Federal Bar # 08469

2

Case 3:00-cv-00662-CFD

Document 60

Filed 03/26/2004

Page 3 of 3

CERTIFICATION

I hereby certify that pursuant to Rule 5(b) of the Federal Rules of Civil Procedure a copy of the foregoing Defendants' Motion for Extension of Time to File Summary Judgment was mailed, first class postage prepaid, this 26th day of March, 2004 to: Marc Glenn, Esq. Law Offices of W. Martyn Philpot, Jr. 409 Orange Avenue New Haven, CT 06511 Tel.: (203) 624-4666

______________________ Beth Z. Margulies Assistant Attorney General

3