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

_, R Case 3:00-cv-OO3%§AHN Document 55 Filed O4/€§2004 Page 1 of 3
UNITED STATES DISTRICT COURT D
DISTRICT CO EC
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i U.S. DlSTRlCTC
I BRIDGEPORIZ CSHST
i WINTHROP HOUSE ASSOCIATION, INC., ) Case No.:
I ) 3-00-CV-328-AHN
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Plaintiff] )
v. )
“ ) ;
l BROOKSIDE ELM ASSOCIATES LIMITED PARTNERSHIP, )
et al. )
)
g Defendants. ) March 31, 2004
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PLAINTIFF’S MOTION FOR EXTENSION OF TIME
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l SUBJECT DECISION: Opinion by Hon. Holly B. Fitzsimmons, dated 12/19/03 I
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_ The plaintiff in the above-entitled Action, Winthrop House Association, Inc. (the
"Association"), hereby files this Local Rule 9(b) Motion for Extension of Time with regard to tiling N
its Local Rule 72.2(a) Objection to the 12/19/03 Opinion of the Hon. Holly B. Fitzsimmons, with
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respect to the above-referenced matter, as follows:
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y 1. The Basis for this Motion. Subsequent to the 2/12/04 Conference with the Court,
at which time the Court issued its Scheduling Order of Briefs, the undersigned has unanticipatedly
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been involved in the following: (i) significant additional time to research and prepare the 2/25/O4
Motion for Summary Judgment (and related documents) in The Calf Island Community Trust, Inc.,
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J Case 3:00-cv-OO3€87AHN Document 55 Filed O4/@2004 Page 2 of 3 i
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K Plaintiffs Motion [or Extension of T imo •Dated March 31, 2004
et al. v. Young Men’s Christian Association of Greenwich, cx//c/ez, et al. , No. 3—O2-CV-462 (AHN); (ii)
significant time to research and prepare a 3/23/04 Supporting Memorandum (on behalf of the Greenwich
YMCA) in comiection with the Government’s 2/25/04 Motion for Partial Summary Judgment on the I
A Pleadings in United States of America v. 28 .8 Acres of Land, More or Less, et al. , No. 3-03 —CV—275 (
i (AHN); and (iii) extensive and newly—arisen multiple pretrial matters with regard to the 5+ M day trial
A in the Stamford Superior Court in L. Scott Frantz v. Rutherford R. Romaine, et al., No. CV—00-
l 0176623 S, which trial is scheduled to commence on 4/1/04. As a result, although the undersigned l
has already spent considerable time preparing the Local Rule 72.2(a) Objection and Memorandum,
the foregoing matters have caused the need for additional time. l
2. Relief Reguested. The undersigned respectfully requests that the time
j deadlines for the filings in connection with the Plaintiff’ s Local Rule 72.2(a) Objection be modified, I
as follows: (i) the Local Rule 72.2(a) Objection shall be mailed on 5/7/04, instead of 4/ 1 6/ 04; and (ii) I
j l the Defendants’ Opposition Memoranda shall be mailed 60 days after 5/ 7/04.
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A 3. Local Rule 9tb)§3} Statements. The undersigned has inquired of opposing i
counsel, who have indicated that they have no position with regard to this Motion. In addition, this L
is to confirm that no previous Motions for Extension of Time have been requested by any party in l
connection with the 12/19/03 Opinion, except for: the P1aintiff"s 1/30/04 Motion for Extension of g
i Time to request that a briefing schedule for the Plaintiff` s Local Rule 72.2(a) Objection be set at the l
2/ l2/04 Conference with the Court. j
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T i Case 3:00-cv-O03€8>)AHN Document 55 Filed 04/ 004 Page 3 of 3 i
Plaintiffs Motion [or Extension of T imo •1)nted March 31, 2004 {
· DATED March 31, 2004 at Greenwich, Connecticut.
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r>LA1Nr1rr1¤ i
Byi
i Philip H. Baitels
i For: Holland, Kaufmann & Bartels, LLC I
Its Attomeys |
i 289 Greenwich Avenue l
Greenwich, CT 06830 \
(203) 869-5600 — (FAX) 869-4648 .
Federal Bar No. ct06836 i
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1 CERTIFICATION
THIS IS TO CERTIFY that a copy of the foregoing shall be mailed this day, postage prepaid, to all i
formal and informal Counsel of Record, and other relevant persons, on March 31, 2004:
Jane I. Milas, Esq. Richard M. Dighello, Jr., Esq.
Garcia & Mills Updike, Kelly & Spellacy
44 Trumbull Street One State Street
New Haven, CT 06510-1001 P.O. Box 231277
Hartford, CT 06123-1277
Thomas W. Witherington, Esq. Robert A. Rubin, Esq. i
Cohn Birnbaum & Shea, PC (The Parties’ Mediator) i
i 100 Pearl Street Postner & Rubin i
Hartford, CT 06103-4500 17 Battery Place
New York, NY 10004-1101
Philip H. Bartels 1
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U :\PHB\CONDOS\W1NTHROP\1\/lotion for Extension of Time.wpd
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