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

i Case 3:03-cv-01050-DJS Document 33 Filed O9/07/2004 Page 1 of 2
i '$t~·-.
i {fhg? /;a¤—,,, M
I (P ·· { 57;,
I OF? - `.., ·
y UNITED STATES DISTRICT COUR " -! ~. 7
DISTRICT OF CONNECTICUT /v/,_
":· -1 `_‘* ` 3(9
MARY SAROJAK 1 CIVIL ACTION NO.:
Plaintiff :
p vs.
THE METALLICS GROUP
D/B/A METALLICS, INC AND :
F. MICHAEL MOLA :
l Defendants. : SEPTEMBER 3, 2004
PLAIN'l`IFF’S MOTION FOR ENLARGEMENT OF TIME l
Pursuant to Rule 6(b) of the Federal Rules of Civil Procedure and 9(b) of the Local Rules of the
l
Civil Procedure, plaintiff] Ms. Mary Sarojak, through her counsel hereby respectfully moves this
i Honorable Court for an enlargement of time ofthirty (30) days, up to and including October 3, 2004.
The additional time requested is lbr the purpose of responding to the Defendant’s Motion for E
l
Summary Judgment dated August 13, 2004.
As good cause for granting the Motion, the Plaintiff, by and through her counsel, represents that
i plaintiffs legal counsel is in good faith attempting to gather the facts and information necessary to
respond to Defendanfs Motion for Summary Judgment.
Defendants’ counsel has been contacted and does not oppose the granting of this Motion.
ORAL ARGUMENT NOT REQUIRED
D TESTIMONY NOT REQUIRED
This is Plaintiff s first Motion for Enlargement of Time.
l
l




< Case 3:03-cv-01050-DJS Document 33 Filed O9/07/2004 Page 2 of 2
{ I WHEREFORE, the Plaintiff respectfully requests that this Honorable Court grant this Motion for
Enlargement of Time.
RESPECTFULLY SUBMITTED, I y
PLAINTIFF,
I MS. MARY SAROJAK
»*"" I
I) V. 1..
I By: Rob rt Fortgang
Federal Bar No. ct 05437
I Robert Fortgang Associates
Greystone Court
573 Hopmeadow Street
Simsbury, CT 06070
I CERTIFICATION {
I hereby certify that I have this 3rd day of September, 2004, mailed a copy of the foregoing,
postage prepaid, to the following counsel of record:
Attorney William Ryan
I Attorney Michael R. Brandt
l Ryan & Ryan, LLC
I 900 Chapel Street
Suite 621
New Haven, Connecticut 065l0
Dated: September 3, 2004
I Plitlti
Robert Fortgang
l