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

Case 3:03-cv-00452-CFD

Document 69

Filed 12/05/2007

Page 1 of 3

UNITED STATES DISTRICT COURT DISTRICT OF CONNECTICUT ) ) Plaintiff, ) ) ) VS. ) ) BETH EL TEMPLE OF WEST ) HARTFORD, INC. ) ) Defendant ) ____________________________________ DAVID RURAN

CIVIL ACTION No. 3:03 CV 452 (CFD)

December 5, 2007

PLAINTIFF'S FIRST MOTION ON CONSENT FOR ENLARGEMENT OF TIME IN WHICH TO FILE AN OPPOSITION TO DEFENDANT'S MOTION TO COMPEL Pursuant to the Federal Rules of Civil Procedure and the Local Rules for this Court, Plaintiff respectfully requests a three (3) week extension of time - up through and including December 27, 2007 - in which to file his Opposition to Defendant's Motion to Compel dated November 15, 2007. In support of this Motion, Plaintiff states as follows: 1. Defendant's Motion to Compel was filed on or about November 15, 2007. Under the applicable rules, Plaintiff's Opposition is due on or before December 6, 2007. 2. Currently, the parties are engaged in settlement discussions under the ongoing supervision and guidance of the Hon. William Garfinkel and are therefore focusing their energies and resources toward reaching a resolution of this matter.

ORAL ARGUMENT NOT REQUESTED TESTIMONY NOT REQUIRED

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Case 3:03-cv-00452-CFD

Document 69

Filed 12/05/2007

Page 2 of 3

3.

In order to avoid the potentially unnecessary expenditure of resources­both by the parties and the Court­the Plaintiff hereby requests an enlargement of time of three weeks in which to file said Opposition on the assumption that within the next week or two the parties will be able to ascertain whether settlement can be achieved at this time.

4. 5.

This is the first enlargement of time sought with respect to this motion. On Monday, December 3, 2007, the undersigned spoke with Joseph Andriola, counsel for Defendant, who stated that the Defendant consents to the granting of this motion.

WHEREFORE, Plaintiff respectfully requests a three (3) week extension of time ­ until December 27, 2007 ­ in which to file his Opposition to Defendant's Motion to Compel.

PLAINTIFF, DAVID RURAN

By:

/s William G. Madsen (ct09853) Madsen, Prestley & Parenteau, LLC 44 Capitol Ave., Suite 201 Hartford, CT 06106 TEL. (860) 246-2466 FAX. (860) 246-1794 Email: [email protected]

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Case 3:03-cv-00452-CFD

Document 69

Filed 12/05/2007

Page 3 of 3

CERTIFICATION OF SERVICE I hereby certify that on this 4th day of December, 2007, a copy of foregoing Motion For Enlargement of Time in Which to File Opposition to Defendant's Motion to Compel was filed electronically [and served by mail on anyone unable to accept electronic filing]. Notice of this filing will be sent by e-mail to all parties by operation of the Court's electronic filing system [or by mail to anyone unable to accept electronic filing]. Parties may access this filing through the Court's system. By: William G. Madsen (ct09853) Madsen, Prestley & Parenteau, LLC 44 Capitol Ave.; Suite 201 Hartford, CT 06106 Telephone: (860) 246-2466 Facsimile: (860) 246-1794 E-mail: [email protected]

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