Free Motion for Extension of Time - District Court of Connecticut - Connecticut

Case 3:03-cv-00452-CFD Document 35 Filed O3/O4/2005 Page 1 of 2
UNITED STATES DISTRICT COURT
DISTRICT OF CONNECTICUT
DAVID RURAN, : CIVIL ACTION NO.:
: 3: 03 CV 452 (CFD)
Plaintiff, :
v. :
BETH EL TEMPLE OF :
WEST HARTFORD, INC., :
Defendant. MARCH 3, 2005
DEFENDANT'S MOTION FOR EXTENSION OF TIME
TO FILE MEMORANDUM IN SUPPORT OF OBJECTION TO RULING ON
PLAINTIFF’S MOTION TO COMPEL AND FOR EXPENSES
The defendant, Beth El Temple of West Hartford, Inc. hereby moves for an extension of
time up to and including March 21, 2005 to file its memorandum in support of objection to ruling
on plaintiffs motion to compel and for expenses.
In support of this motion, the defendant, through counsel, represents the following:
l. Counsel for the defendant only recently received the Ruling on Plaintiff s Motion
to Compel and for Expenses.
2. Counsel for the defendant will be on vacation from March 5, 2005 to March I3,
2005.
3. The Defendant’s Objection, stating the grounds therefore, has been filed herewith;
however, Counsel requires more time to adequately prepare defendant’s memorandum.
3. Pursuant to Local Rule 9(b)(3), defendant’s counsel has inquired of opposing
counsel, William Madsen, who stated during a telephone conference on March 3, 2005 that the
plaintiff has no objection to this motion.

Case 3:03-cv-00452-CFD Document 35 Filed O3/O4/2005 Page 2 of 2
BETH EL TEMPLE OF
WEST HARTFORD, INC.,
By Its Attorneys,
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Fed Bar # ct07991
FITZHUGH, PARKER & ALVARO LLP
One Constitution Plaza, Suite 900
Hartford, CT 02110
(860) 549-6803
Certificate of Service
The undersigned hereby certifies that on November 8, 2004, a copy of the above
document was sent to William G. Madsen, counsel for the plaintiff at Madsen, Prestley &
Parenteau, LLC, 44 Capitol Ave., Suite 201, Hartford, CT 06106, by first class mail, postage
prepaid.

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