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

Case 3:03-cv-00149-WIG

Document 163

Filed 08/18/2005

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)

AUGUST 18, 2005

PLAINTIFF'S FIRST MOTION FOR EXTENSION OF TIME Plaintiff Ferron Shorter Jr., by and through his undersigned counsel, respectfully requests an extension of twenty-two (22) days, from August 18, 2005 until September 9, 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 is due August 18, 2005. 3. Plaintiff requests an additional twenty-days (22) to respond and provides as good cause the press of business during the past three weeks and through August 23, 2005, including an opposition to summary judgment memorandum in the matter of Saviano v. Town of Westport, Case No. 3:03-cv-522(RNC) due on August 22, 2005, and a trial memorandum and jury selection scheduled for September 8, 2005, in the matter of Mrs. B. v. Litchfield Board of Education, Case No. 3:03-cv-1152(PCD). 4. Counsel for Defendant was contacted by the undersigned regarding Plaintiff's extension request and subsequently conveyed Defendant's objection to the requested extension.

Case 3:03-cv-00149-WIG

Document 163

Filed 08/18/2005

Page 2 of 2

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 First Motion for Extension of Time was mailed, first-class, postage-paid, on August 18, 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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