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

Case 3:03-cv-00149-WIG

Document 153

Filed 06/22/2005

Page 1 of 2

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

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

JUNE 22, 2005

PLAINTIFF'S SECOND MOTION FOR EXTENSION OF TIME Plaintiff Ferron Shorter Jr., by and through his undersigned counsel, respectfully requests an extension of two days, from June 22, 2005, to June 27, 2005, to comply with an Order of the Court instructing Plaintiff to: [S]ubmit a calculation of the amount of prejudgment interest from January 23, 2002, to the date of this ruling, compounded either monthly or biweekly (depending on how Plaintiff was paid by The Hartford), using the weekly rate of interest under § 1961(a) as of the Friday on or immediately preceding the date on which Plaintiff would have been paid. See E.E.O.C. v. Yellow Freight System, 2002 WL 31011859, at *33. This calculation should be submitted within twenty (20) days of the date of this ruling, to which defense counsel will have ten (10) days to object and, if so, to offer an alternative calculation. Either side may enlist the help of an expert not previously disclosed in the trial memorandum.

In support of the instant request, undersigned counsel represents that due to time required in preparing summary judgment opposition papers in the matter of Branciforte v. Town of Middletown, et al., Case No. 3:02-cv-928(AVC) for filing on June 22, 2005,1 and the expiration of a discovery deadline in Crocco v. Advance Auto Parts, et al., Case No. 3:04-cv-1608(JCH) on June 25, 2005, Plaintiff's undersigned counsel requires until June 27, 2005, to finalize Plaintiff's submission in response to the Court's May 31, 2005, Order.
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Previous deadline of June 20, 2005, extended to June 22, 2005.

Case 3:03-cv-00149-WIG

Document 153

Filed 06/22/2005

Page 2 of 2

An e-mail was forwarded to counsel of record for Defendant during the morning of June 22, 2005, but opposing counsel did not have opportunity to respond.

PLAINTIFF FERRON SHORTER JR.

BY:

________________________________ Rachel M. Baird (Fed. Bar No. 12131) 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 Motion for Extension of Time was mailed, first-class, postage-paid, on June 22, 2005, to: James F. Shea Jackson Lewis LLP 90 State House Sq Fl 8 Hartford CT 06103-3708 __________________________ Rachel M. Baird

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