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

Case 3:03-cv-00149-WIG

Document 168

Filed 09/13/2005

Page 1 of 2

UNITED STATES DISTRICT COURT DISTRICT OF CONNECTICUT FERRON SHORTER JR., Plaintiff, v. HARTFORD FINANCIAL SERVICES GROUP, INC., Defendant. : : : : : : : : :

CASE NO.: 3:03-cv-149(WIG)

SEPTEMBER 13, 2005

PLAINTIFF'S THIRD MOTION FOR EXTENSION OF TIME Plaintiff Ferron Shorter Jr., by and through his undersigned counsel, respectfully requests an extension of three (3) days from September 13, 2005, until September 16, 2005, to file Plaintiff's Memorandum of Law in Opposition to Defendant's Motion for Judgment as a Matter of Law. 1. Defendant filed a Motion for Judgment as a Matter of Law on July 28, 2005. (doc. # 161) 2. Plaintiff's response was due August 18, 2005. 3. Plaintiff requested and was granted an additional twenty-two (22) days, until September 9, 2005, to respond to Defendant's JMOL. 4. Plaintiff's counsel requested and was granted an additional four (4) days from September 9, 2005, until September 13, 2005, and offered as cause the necessity of reviewing the trial transcript which Plaintiff's counsel did at the clerk's office on September 12, 2005. 5. If the instant motion is granted, the requested continuances will total less than thirty (30) days. 6. As good cause, counsel represents that since Sunday, September 11, 2005, a new client has required substantial time and immediate attention to address his three million dollar

Case 3:03-cv-00149-WIG

Document 168

Filed 09/13/2005

Page 2 of 2

bond and sealed warrant at the Superior Court in Litchfield. 7. Defendant's counsel has indicated an objection to Plaintiff's request for any extension of time.

PLAINTIFF FERRON SHORTER JR.

BY:

/s/ Rachel M. Baird Rachel M. Baird (ct12131) Law Office of Rachel M. Baird 379 Prospect Street Torrington CT 06790-5239 Tel: (860) 626-9991 Fax: (860) 626-9992 E-mail: [email protected]

CERTIFICATION I HEREBY CERTIFY THAT the foregoing Plaintiff's Third Motion for Extension of Time was mailed, first-class, postage-paid, on September 13, 2005, to: Margaret J. Strange Jackson Lewis LLP 90 State House Sq Fl 8 Hartford CT 06103

/s/ Rachel M. Baird Rachel M. Baird

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