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

Case 3:00-cv-00854-CFD

Document 69

Filed 08/19/2005

Page 1 of 4

UNITED STATES DISTRICT COURT DISTRICT OF CONNECTICUT LAWRENCE KALADISH, : : Plaintiff, : : VS. : : CROMPTON CORPORATION, : CROMPTON & KNOWLES : CORPORATION, UNIROYAL CHEMICAL : CORPORATION, UNIROYAL : CHEMICAL COMPANY, INC., : UNIROYAL, INC. AND UNIROYAL : HOLDING, INC. : Defendants :

CIVIL ACTION NO. 3:00 CV 854 (CFD)

AUGUST 18, 2005

MOTION TO EXTEND TIME TO FILE APPEAL Pursuant to Title 28 U.S.C. §2107(c), the Plaintiff, Lawrence Kaladish, respectfully requests this Court to extend the time in which to file an appeal of the Court's Ruling on Defendants' Motion for Summary Judgment, for which Judgment in favor of the Defendants was entered on August 10, 2005. The Plaintiff represents that good cause exists for this request as described below. 1. The Judgment was entered on August 10, 2005. 2. Notice of the Ruling on Defendants' Motion for Summary Judgment and the Judgment was emailed to me at my office via the CMECF system on August 11, 2005. 3. A copy of the Ruling on Defendants' Motion for Summary Judgment and the

Case 3:00-cv-00854-CFD

Document 69

Filed 08/19/2005

Page 2 of 4

Judgment was sent to me via regular mail on August 11, 2005, which was received by my office on August 12, 2005. 4. I was out of the office on vacation the entire week of August 8, 2005 and did not return to the office until Monday, August 15, 2005. 5. I am the only attorney in the office familiar with this file. Although my secretary told me on Friday, August 12, 2005 that we had received copies of the Ruling on Defendants' Motion for Summary Judgment and the Judgment in the mail, I was unable to begin review of the documents to assess my client's rights of appeal until I returned to the office on August 15, 2005. 6. Since I returned to the office on August 15, 2005, I have sent copies of the Ruling on Defendants' Motion for Summary Judgment and the Judgment to my client via email, facsimile and federal express. I have also called my client and left a message on his answering machine. 7. As of the signing of this Motion, I have not heard back from my client. I am unable to determine whether or not he is on vacation, and, therefore, unable to determine if he knows that judgment has been entered.

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Case 3:00-cv-00854-CFD

Document 69

Filed 08/19/2005

Page 3 of 4

8. I have contacted the attorney for the defendants and she has no objection to this requested extension. 9. This is the Plaintiff's first request to extend the time in which to appeal. WHEREFORE, the Plaintiff respectfully requests that the time in which to file an appeal be extended for twenty (20) days up to and including September 29, 2005. THE PLAINTIFF, Lawrence Kaladish

By:

______ Louis J. Bonsangue (CT14586) Jacobi, Kappel & Case, P.C. 300 Bic Drive Milford, Connecticut 06460 Telephone #: (203) 874-7110 His Attorney

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Case 3:00-cv-00854-CFD

Document 69

Filed 08/19/2005

Page 4 of 4

CERTIFICATION OF SERVICE This is to certify that on the 18th day of August, 2005, a copy of the foregoing was mailed, postage prepaid, to the following: Attorney Susan H. Shumway Shumway & Spencer, LLC 155 Post Road East Suite 12 Westport, Connecticut 06880 ___________________________________ Louis J. Bonsangue

F:\WPDOCS\JEANPUB\LOU\kaladish\court\Motion to Extend Time to Appeal.doc

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