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

Case 3:00-cv—00656-SRU Document 67 Filed 11/17/2003 Page 1 of 3
UNITED STATES DISTRICT COURT
DISTRICT OF CONNECTICUT
MARSHALL CHAMBERS, : Docket No. 3:00CV00656(SRU)
Plaintiff, Z
v.
ANTHONY J. PRINCIPI
SECRETARY, U.S. DEPARTMENT :
OF VETERAN’S AFFAIRS :
Defendant. NOVEMBER 14, 2003
MOTION FOR EXTENSION OF TIME TO
SUBMIT JOINT TRIAL MEMORANDUM
Pursuant to Rule 7 of the Local Rules of Procedure for the District of Connecticut
and the Order of this Court, Defendant, Anthony J. Principi, Secretary of Veterans ·
Affairs, hereby respectfully submits this motion for extension of time within which to
submit the Joint Trial Memorandum in the above-captioned action. Pursuant to the
Order of this Court entered on September 23, 2003, the Joint Trial Memorandum is due
on November 30, 2003.
An extension of this deadline is sought because of defendant’s Motion for
Reconsideration of this Court's Ruling on defendant’s Motion for Summary Judgment
entered on September 22, 2003. In this ruling the Court granted the defendant’s
motion in all respects except as to one claim in Count I, and the claims in Count VII.
Defendant has asked the Court to reconsider its decision to sustain Count VII of the
Complaint alleging constructive discharge. This motion is pending before the Court.

Case 3:00-cv—00656-SRU Document 67 Filed 11/17/2003 Page 2 of 3
The Court’s ruling on defendant’s Motion for Reconsideration will affect the
parties’ Joint Trial Memorandum. Ifthe motion is granted and Count VII dismissed, the
parties need not address or present evidence on the issue of constructive discharge. If
the motion is denied, Count VII will need to be addressed by the parties.
In light of the foregoing, the defendant requests that this Court extend the time
for filing the Joint Trial Memorandum until 30 days after this Court’s ruling on the
defendants Motion for Reconsideration, and that the Court’s December 9, 2003 Trial
Calendar Call for this case be continued accordingly.
This is the first motion for extension of this time deadline. Plaintiffs counsel
could not be reached to ascertain his position with regard to the extension sought.
Respectfully submitted,
KEVIN J. O'CONNOR
UNITED STATES ATTORNEY
_4,. J /élc//I/U\ 5/-dia
l LAUREN M. NASH
ASSISTANT U.S. ATTORNEY
P.O. BOX 1824
NEW HAVEN, CT 06508-1824
(203) 821-3700
FEDERAL BAR # ct01705
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Case 3:00-cv—00656-SRU Document 67 Filed 11/17/2003 Page 3 of 3
CERTIFICATE OF SERVICE
This is to certify that a copy of the within and foregoing Motion for Extension of
Time to Submit Joint Trial Memorandum has been sent via first class mail, postage
prepaid, on this 14"‘ day of November, 2003, to:
Caleb M. Pilgrim, Esq.
Law Offices of Caleb M. Pilgrim, LLC
1404 Whalley Avenue, 2"" Floor » `
New Haven, CT 06515 ‘
,,,,/ mma I W M L
AUREN M. NASH
ASSISTANT U.S. ATTORNEY
P.O. BOX 1824
NEW HAVEN, CT 06508
(203) 821 -3700
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