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

. Case 3:03-cv-004555/IRK Document 36 Filed 05/1 1[2004 Page 1 of 2
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UNITED STATES DISTRICT COIJRTAT pi
DISTRICT OF CONNECTIHUT i ’‘a‘ ‘ *·l‘
W { ·. an .
Kerin Carmody S {T Ig i *‘ "·*- I ll Ur} .
; Civil A¤ri6i&‘Na; VS I 2 303CV00456 (MRK) _
Koh1’s Department Stores, Inc.
Defendant : May 07, 2004 i
PLAINTIFF’S MOTION FOR EXTENSION OF TIME TO RESPOND T0
DEFENDANT’S MOTION FOR SUMMARY JUDGMENT \
_ The Plaintiff; Kerin Carmody, in the above—captioned matter, pursuant to Local Rule 7
a
!
(b), respectfully request an extension of time until June 18, 2004 to respond to the Defendant’s l
Motion for Summary Judgment dated April 26, 2004 based on the following:
l. This is the first request for a continuance in the above-matter.
2Q The current pretrial deadlines call for completion of discovery on June Ol, 2004 with R
- dispositive motions to be filed on or before July Ol , 2004.
3. Pursuant to the last conference with the court the Plaintiff has received further discovery I
information concerning other incidents with the Defendant which may yield further relevant

evidence in response to the Defendant’s Motion For Summary Judgment. g
4. Cotmsel for the Piaintiff l1as a scheduled vacation the third week of May.
5. ` Defense counsel has been consulted and there is an objections to this motion.
Wherefore, for the foregoing reasons the plaintiff respectfully requests this court grant .
- this motion for extension of time. i
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. . Z: Case 3:03-cv-00456=I\§IRK Document 36 Filed 05/1 j/%004 Page 2 of 2
K-, lg,.
` THE PLAIN TIFF, I
KERIN CARMODY
A
BY¤
‘ · RICHARD I-I. GREENE, CT08905 |
LAW OFFICE OF RICHARD GREENE ` I |
431 HOWE AVENUE `
P.O. BOX 2042
SHELTON, CT 06484 _
~ , CERTIFICATION E
This is to certiiy that a copy of the foregoing Extension of Time has been served
pursuant to local rule $(1) via fax and niailed on this date, May 07, 2004, postage prepaid,
to all counsel and pro se parties of record: I
_ Barry Beletsky, Esq., I _
David J. Baker, Esq. l
Ricco & Beletsky `
310 Main Street, Suite 2B _
East Haven, CT 06512 “ I
Richard H. Greene l I
I , i

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