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

Case 3:03-cv-00149-WIG

Document 166

Filed 09/09/2005

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 9, 2005

PLAINTIFF'S SECOND MOTION FOR EXTENSION OF TIME Plaintiff Ferron Shorter Jr., by and through his undersigned counsel, respectfully requests an extension of four (4) days, from September 9, 2005, until September 13, 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 requests an additional four (4) days for the opportunity to review the trial transcripts located in the court clerk's file on Monday, September 12, 2005, prior to filing the response to the JMOL. 5. Plaintiff's counsel anticipated reviewing the trial transcripts during the afternoon of September 8, 2005, but was unexpectedly engaged in jury selection and other related matters until 5:30 PM in the matter of Mrs. B., et al. v. Litchfield Board of Education, et al., 3:03-cv-1152(PCD).

Case 3:03-cv-00149-WIG

Document 166

Filed 09/09/2005

Page 2 of 2

6. 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 Second Motion for Extension of Time was mailed, first-class, postage-paid, on September 9, 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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