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

Case 3:03-cv-00555—FINC( Document 60 Filed 12/14/2004 Page 1 of 3
_ UNITED STATES DISTRICT COURT
‘ FOR THE
- DISTRICT OF CONNECTICUT
RONNI RABIN,
MARITZA AVILA, I
JANE DOE,
RONALD GREEN,
WENDE QALLAB,
LINDA SIEBERT, and
ALLISON PAYNE ` CIVIL ACTION NO.3:03 CV555 (RNC)
Plaintiffs, * _
Individually and as
. representatives of all
. persons similarly situated
VS. · W
PATRICIA WILSON-COKER, _
Commissioner ofthe Connecticut DECEMBER 13, 2004
Department of Social Services,
in her official capacity,
Defendant.
PLAINTIFFS’ MOTION FOR EXTENSION OF TIME .
TO RESPOND TO _DEFENDANT’S OPPOSITION TO FEE PETITION
Plaintiffs hereby request an extension of time until January 7, 2005 to respond to
defendant’s Memorandum in Opposition to Motion for Feesand Costs which defendant
filed on December 3, 2004. In support thereof, plaintiffs state that plaintiffs filed their
Motion for Attorneys Fees and Costs on October 14, 2004 to avoid any possible
jurisdictional claim. The motion was filed without accompanying affidavits or time
records because the parties were, at that time, attempting to resolve this matter.
Accordingly, plaintiffs need to submit fee affidavits from each of plaintiffs counsel and
affidavits supporting counsels; hourly rates. Plaintiffs also need to file a brief replying to
the matters raised by defendants Memorandum. Plaintiffs respectfully request that

Case 3:03-cv-00555-BNC Document 60 Filed 12/14/2004 Page 2 of 3
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_ they be given until after the holidays to submit these documents. This is plaintiffs’ first
request for an extension of time on this matter, and defendant has consented to this
request.
l Respectfully submitted,
· PLAINTIFF-APPELLANTS
l ‘/_\¥ l
ii UW U
_ I By: / ‘
. SHE L A. WHITE ct 5727)
JOANNE G. GlBAU‘ t05730)
- New Haven Legal Assistance Association.
426 State Street
. New Haven, CT 06510
Phone: 203.946-4811 x 116
FAX: 203.498-9271
[email protected]
LUCY POTTER(ct23449) S
GREG BASS (ct18114) F
Greater Hartford Legal Aid
999 Asylum Avenue, 3'°‘ Floor
· Hanford, CT 06105-2465
. Phone: 860.541.5002
Fax: 860.541.5050 .
[email protected]
[email protected]
~ SHARON LANGER(ct06907)
Connecticut Legai Service, inc.
‘ 587 Main Street
- New Britain, CT 06051
Phone: 860.225.8678 x108
“ Fax: 860.225.6105
sianger@conniegalsenricesorg
THEIR ATTORNEYS

Case 3:03-cv-00555-BNC Document 60 Filed 12/14/2004 Page 3 of 3 _
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CERTIFICATION `
I hereby certify that a copy of the foregoing PIaintiffs’ Motion for Extension of
?
‘ Time to Respond to Defendants Opposition to Fee Petition was mailed in accordance
with Rule 5(b) of the Federal Rules of Civil Procedure on this 13th day of December,
- 2004, first class mall, postage prepaid to: -
Hugh Barber
Tanya Fellciano
’ Richard J. Lynch ‘
Assistant Attorneys General
55 Elm Street, P.O. B 20
Hartford, CT 06141-07620 _\
Shelley A. White U
Plaintiffs’ Attorne ·