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

. {P llnl "m_w Case;;(§5QDD;4wb—CFD Document 128 ' Filed O2/11/2005 Page 1 of 3 /
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(NW UNITED STATES DISTRICT COURT R
DISTRICT OF CONNECTICUT `
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CLARENCE R. COLLINS, JR., et al, T
piaimiffs l 2:,, .`‘- 5 iii. i,
VS. : ‘
OLIN CORPORATION, et al,
Defendants FEBRUARY 8, 2005
CONSENTED-TO MOTION TO AMEND SCHEDULING ORDER i
The plaintiffs, on consent of defendant Town of Hamden, hereby move theiCourt to
modify the Scheduling Order in this case, so as to allow them an additional three weeks within
which to file their opposition to the Town’s Motion for Partial Summary Judgment. In support,
movants state as follows:
1. Under the Scheduling Order, as amended, the plaintiffs have until Febtuary 15,
2005 to file their memorandum and supporting materials in opposition to Olin’s motion. F
2. Because of the complexity of the issues raised by the Town’s motion, and, in
particular, because of the number of facts and age of the factual record involved, it has taken
plaintiffs’ counsel longer than anticipated to complete their responsive papers. Q
3. The Town’s counsel does not object to the extension requested, provided that
there is a corresponding extension of time within which they may tile their reply brief ali support
of the motion to April 8, 2005. *
4. The remaining deadlines set forth in the Scheduling Order as amended by the
Court on February 2, 2004; May 4, 2004; August 19, 2004; October 25, 2004; and Deceinber 16,
2004 shall remain the same. {
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__ _ _ Case 3:03-cv-00945-CFD Document 128 Filed 02/11/2005 Page 2 of 3
WHEREFORE, the plaintiffs respectfully request that the Court modify the Scheduling
Order in this case to allow them until March 8, 2005 within which to file their opposition to the
Town’s Motion for Partial Summary Judgment, and to allow defendant Town of Hamden until (
April 8, 2005 within which to tile its reply brief in support of the motion. R
THE PLA TIFF
By_r
Mark Roberts, Es . (Fed Bar # ct25062)
Andrew Rainer, Esq. (Fed Bar #ct25938) l
g·ainer(@,mcrobertslaw.com
McRoberts, Roberts & Rainer, L.L.P.
53 State Street
Boston, Massachusetts 02114
Tele: (617) 722-8222
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David B. Zabel, Esq. ct01382
@[email protected]
Monte E. Frank, Esq. ct13666
m__franl<(@cohenandwol£com
Cohen and Wolf, PC
1115 Broad Street i
Bridgeport, Connecticut 06604
Tele: (203) 368-0211
Neil T. Leifer, Esq.
meifer ten1aw.com
Thomton & Naumes L.L.P ’
100 Summer Street, 30th Floor
Boston, Massachusetts 02110
Tele: (617) 720-1333 J
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_ Case 3:03-cv-00945-CFD Document 128 Filed 02/11/2005 Page 3 of 3 A
I CERTIFICATION
This is to certify that on this Sth day of February, 2005, I hereby mailed via first class
mail a copy of the foregoing to: ‘
Michael H. Wetmore, Esq.
Joel B. Samson, Esq.
Husch & Eppenberger, LLC
190 Carondelet Plz Ste 600
Saint Louis MO 63105-3433
Sandra K. Davis, Esq.
Mark S. Baldwin, Esq.
Brown Rudnick Berlack Israels LLP j
185 Asylum St Fl 38
Hartford CT 06103-3408
Ann M. Catino, Esq, I
Joseph Former, Esq.
Halloran & Sage, LLP
One Goodwin Square
225 Asylum Street
Hartford, CT 06103
Knzdrew A. Raineri
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