Free Motion for Extension of Time to File Response/Reply to Motion - District Court of Connecticut - Connecticut

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I ., . Case 3:03-cv-007126/ISWE Document 77 Filed O9/2gL§OO4 Page 1 of 3 I
UNITED STATES DISTRICT COURT
DISTRICT OF CONNECTICUT
GERTRUDE BAYONNE, :
Plaintiff, i
: Civ. Action No. I
3:03CV07l2(WWE)
V. Z
PITNEY BOWES, INC., :
Defendant. SEPTEMBER 24, 2004
PLAINTIFFS’ MOTION FOR EXTENSION OF TIME TO FILE
MEMORANDUM OF LAW IN OPPOSITION TO DEFENDANTS’—
MOTION T0 COMPEL AND JOINT MOTION TO EXTEND ZL?
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Plaintiff Gertrude Bayonne hereby respectfully requests an extension oftimeato . I
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file a Memorandum of Law in Opposition to the Defendants’ Motion to Compel daigizl I
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September 7, 2004, pursuant to Local Civil Rule 9(b). Plaintiff requests an additional I
thirty (30) days from the date the original responsive pleading was due to be tiled, I
October l, 2004. The Defendants motion failed to include a certification page, thus the I
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undersign can only presume the deadline is twenty days from the date of the motion, plus
three days for delivery by first class mail. The proposed new deadline for filing Plaintiffs
memorandum of law in opposition will be up to and including October 31, 2004. I
Plaintiff asserts that good cause exists for granting the instant motion: 1)
Plaintiffs counsel needs additional time to prepare a responsive pleading to Defendants
Motion to Compelg 2) the undersigned has previously scheduled a lengthy vacation; and
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l ` i Case 3:03-cv-OO712 E Document 77 Filed O9/2 f O4 Page 2 of 3
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3) the undersigned has had preexisting litigation work to be completed prior to vacation
which prevent the review and preparation of a responsive brief
Counsel for Plaintiff contacted counsel for the Defendant on September 23, 2004,
who consented to the instant motions. U
Plaintiff also moves to extend the deadline for completion of discovery by thirty
(30) days, from the current deadline of January 15, 2005. The new proposed deadline will
be February 14, 2005. This is a joint motion, proposed by the Defendants, and
communicated to the undersigned on September 23, 2004, who consent. This is the
parties first joint motion for extension of the discovery deadline.
This is Plaintiff s first request for an extension of time to file a responsive
pleading to the Defendants’ Motion to Compell. I
Dated: Southport, CT PLAINTI F, =
September 24, 2004 GER. ' U4! BAYONNE l
Byr -
Mak P. car 828)
Carey & Associates, P.C.
Attorneys At Law
71 Old Post Road, Suite One
Southport, CT 06490
(203) 255-4150 tel.
(203) 255-0380 fax.
[email protected] g
Attorney for Plaintiff I
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l U Case 3:03-cv-OO712C%WE Document 77 Filed O9/2Zf%OO4 Page 3 of 3 f
CERTIFICATE OF SERVICE
THIS IS TO CERTIF Y, that the foregoing was delivered via first class mail,
postage prepaid, this the 24"` day of September, 2004 to:
John Stretton l
Edwards & Angell, LLC
Three Stamford Plaza
301 Tresser Boulevard
Stamford, CT 06901
» Z:-.2.
Mark P. Carey
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