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

Case 3:03-cv-00713-AWT Document 18 Filed 07/14/2004 Page 1 of 3
LAw DEPARTMENT
NORTHEAST AREA OFFICE
UNITED STATES
—`—_;T*—
July 13, 2004
Clerk,
United States District Court
. 450 Main Street
Hartford, CT 06103-3002
Re: Patricia Hoey v. J. Potter
Civil Action No. 3:03CV713 (AWT)
To Whom lt May Concern:
Enclosed for filing please find Defendants Motion for Enlargement of Time and same
recorded on floppy disk.
Very truly yours,
KEVIN J. O’CONNOR
Mm M/M an/F
Anna V. Crawf
Special Assistant U.S. Attorney
Enclosures
cc; Charles Parks, Esquire
8 GRu=i=iM Row Norm-i
Wnvoson CT 06006-0170
TEL: issolzssvaos
Fm (eso) 285-7397

Case 3:03-cv-00713-AWT Document 18 Filed 07/14/2004 Page 2 of 3
UNITED STATES DISTRICT COURT
DISTRICT OF CONNECTICUT
..............-...................................-.... X
PATRICIA I-IOEY,
Plaintiff,
v. Civil Action No. 303CV713 (AWT)
JOHN E. POTTER,
POSTMASTER GENERAL,
UNITED STATES POSTAL SERVICE
July 13, 2004
Defendant.
.................~......... s ................. .. ......... X
MOTION FOR ENLARGEMENT OF TIME
Defendant, John E. Potter, Postmaster General, United States Postal Service,
respectfully requests an enlargement of time until July 22, 2004 to file a Motion for
Summary Judgment in this matter for the reason that the undersigned has learned that
one of Defendants witnesses, who is needed to sign an affidavit to accompany the
motion, is on vacation this week. Therefore, he is unable to review and sign his affidavit
until the week of July 19. As a result, the Defendant is unable to complete the papers
accompanying the motion by the present deadline of June 16, 2004.
Plaintiffs counsel’s office was twice contacted on today's date, but he was not
available to respond to Defendants request for his position with respect to this motion.
This is Defendants second request to extend the motion deadline.
Respectfully submitted,
KEVIN J. O’CONNOR,
UNITED STATES ATTORNEY
By: MWLI
Anna V. Crawf rd
Special Assista U.S. Attorney
United States Postal Service
‘ 8 GrifHn Road North
Windsor, CT 06006-0170
Tel. (860) 285-7309
Fax: (860) 285-7397
Fed. Bar No. ct01394

Case 3:03-cv-00713-AWT Document 18 Filed 07/14/2004 Page 3 of 3
CERTIFICATE OF SERVICE
I hereby certify that a copy of the Assented to Motion for Enlargement of Time
was sent by First Class Mail, this 13th of July, 2004, to:
PIaintiff’s Regresentative
Charles G. Parks, Jr.
Parks & Associates
800 Summer Street, Suite 509
Stamford, CT 06901
6(Mw/¤r>~ C/\¢`I»·v~/lg
Anna V. Crawford
2