Free Motion for Leave to File - District Court of Connecticut - Connecticut

i Case 3:03-cv-00712-WWE Document 93 Filed O1/28/2005 Page 1 of 2
i O i
UNITED STATES DISTRICT COURT 1 1 in . A `.
DISTRICT OF CONNECTICUT
_¥_’_fi Qlj fl QH il? I
GERTRUDE BAYONNE, : . `_ i
Plaintiff, .
: Civ. Action N0.
3:03CV0712(WWE)
V. Z j
PITNEY BOWES, INC., et al. : i
Defendants. January 28, 2005
PLAINTIFF’S MOTION TO FILE A NUNC PRO TUNC OBJECTION TO i
MAGISTRATES DECISIONGRANTING MOTION TO COMPEL WITH FEES
This is Plaintiffs Motion to file a nunc pro tune objection to the Court’s January =
14, 2005 Order granting Defendants Motion to Compel and fees and costs. Good cause i
i
exists for granting the instant motion. The original deadline for filing any objection to
the Court’s January 14, 2005 Order was January 24, 2005. Plaintiffs counsel was — j
prevented from filing a timely motion due to an overburdened case load, filing a i
supplemental response to Defendants First Set of lnterrogatories (155 pages in length), j
and dealing with a personal family crisis}
Plaintiff has filed her Objection to the Court’s January 14, 2005 Order on this i
date. This is Plaintiff s first request to file such motion. Plaintiff contacted counsel for the p
Defendants on this date, who did not consent to the instant motion.
Plaintiff respectfully requests that the Court grant the instant motion.
i
I Plaintiffs counsel father underwent cardiac surgery at Yale New Haven Hospital on January 14, 2005, i
and much of his time was taken dealing with this family matter.

` 5 ’‘e‘

` ‘e‘e

I U-——_—ff
i Case 3:03-cv-OO712-WWE Document 93 Filed O1/232005 Page 2 of 2 l
l j hw,)
GERTRUDE BAYONNE ;
Plaintif . =
Z 4 i '
Mark P. c 7828) I (
Carey & · · ciates, P.C. l
71 Old Post Road, Suite One
Southport, CT 06890
(203) 255-4150 tel. I
I (203) 255-0380 fax.
Mca1·[email protected] i
I-Ier Attorney - I
I
l
l
CERTIFICATE OF SERVICE
!
THIS IS TO CERTIFY, that the foregoing was delivered via first class mail,
postage prepaid, this the 28"` day of January, 2005 to: 2
John G. Stretton
Edwards & Angell, LLC
Three Stamford Plaza l
301 Tresser Boulevard l
Stamford, CT 06901 P, (
H W _ .
A i
. ·. P. C (
I l
l
l
2
1
#——— ‘_“' ___””""""`""`”m—””—F”—??