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

. Case 3:03-cv-01055-AVC Document 77 Filed 12/06/2005 Page1 of 3
UNITED STATES DISTRICT COURT
DISTRICT OF CONNECTICUT
DOLORES FONSECA, RAFAEL FONSECA, z CRIMINAL ACTION NUMBER
AND MELANIE FONSECA, :
Plaintiffs, 2 3:03cv01055(AVC)
v.
JASON ALTERIO, JORGE LARREGUI,
AND THE CITY OF BRIDGEPORT :
Defendants : DECEMBER 5, 2005
PLAINTIFF’S FIRST REQUEST FOR EXTENSION OF TIME TO RESPOND TO
DEFENDANTS’ MOTION FOR SUMMARY JUDGMENT.
The plaintiffs, DOLORES, RAFAEL AND MELANIE FONSECA, move this Court
to grant them an extension of time up to and including January 9, 2006 to respond to
the motions for summary judgment filed by all defendants in this case.
In support of this Motion, counsel for the plaintiffs represent as follows:
1. Defendant Jason Alterio filed a Motion for Summary Judgment and
supporting documentation on or about November 8, 2005.
. 2. Defendant Alterio’s moving papers were not received by plaintiffs counsel
until on or about November 15, 2005.
3. Defendants Larrequi and the City of Bridgeport also filed Motions for
Summary Judgment on or about November 10, 2005.
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Case 3:03-cv-01055-AVC Document 77 Filed 12/06/2005 Page 2 of 3
4. However, counsel for defendants Larregui and the City of Bridgeport
certified those defendants moving papers to plaintiff Dolores Fonseca
rather than to plaintiffs undersigned counsel.
5. As a result, pIaintiffs’ undersigned counsel did not receive defendant
l.arregui’s and City of Bridgeports moving papers until on or about
November 21, 2005.
6. Undersigned counsel for the plaintiff has been involved in a civil trial since
November 1, 2005. That trial is still ongoing at this time in the New Haven
Superior Court, in the matter of Snyder vs. Cedar, Docket No. CV01—
0454296 S,
7. Because of the upcoming holidays and a planned family vacation to
Florida during that time, undersigned counsel for the plaintiff is requesting
an extension of time, up to and including January 9, 2006, to respond to
all defendants’ Motions for Summary Judgment.
8. Counsel for the defendants, Elliot Spector, Esquire and Attorney Barbara
Brazzel-l\/lassaro, have no objection to the requested extension of time.
9. This is the first request for extension of time in connection with the
pending motions for summary judgment.
10. There is good cause for granting this request.
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Case 3:03-cv-01055-AVC Document 77 Filed 12/06/2005 Page 3 of 3
11. No trial date has been set as of this time.
THE PLAINTIFFS,
DOLORES FONSECA, RAFAEL FONSECA
AN ll/IELANIE FO ECA
BY: I ··-—.t. - .... --
POLAN
Law Offices of Attorney Diane Polan, LLC
129 Church Street, Suite 802
New Haven, CT 06510
[email protected]
Telephone: 203-865-5000
Facsimile: 203-865-2177
Federal Bar No. ct00223
Their Attorney
CERTIFICATION
This is to certify that a copy of the foregoing has been sent via electronic mail,
this 5th day of December, 2005, to the following counsel and parties of record:
Attorney Barbara Brazzel-ll/Iassaro
Office of the City Attorney
999 Broad Street, 2"°* Floor
Bridgeport, CT 06604-4328
E-mail: [email protected]
Elliot B. Spector, Esquire ·
Noble, Spector, Young & O'Connor
One Congress Street, Fourth Floor .
Hartford, CT 06114
E-mail: [email protected]
DIANE Pot lnflf ii‘:‘·~·::·— ...... _,_,,%g_
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