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

Case 3:03-cv-00149-WIG

Document 144

Filed 04/08/2005

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

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

APRIL 8, 2005

PLAINTIFF'S FIRST MOTION FOR EXTENSION OF TIME Plaintiff Ferron Shorter Jr., by and through his undersigned counsel, and pursuant to Local Civil Rule 7(b) of this District, moves for an extension of fourteen (14) days, until April 22, 2005, to reply to Defendant's opposition to Plaintiff's motions for attorney's fees and equitable relief. 1. Defendant responded to Plaintiff's motions for attorney's fees and equitable relief

(doc. ##140, 141) on March 29, 2005, after receiving, absent objection, extensions granted on March 16, 2005, and March 22, 2005, respectively, to respond. (doc. ##136, 137 and 138, 139) 2. 3. Plaintiff's replies are due April 8, 2005. Plaintiff requests an additional fourteen (14) days until April 22, 2005, to respond

and as good cause represents that through April 5, 2005, Plaintiff's counsel has been occupied in responding to a seventy page summary judgment motion and 206 item Local Rule 56(a)1 Statement filed in the matter of Solomon v. Hartford Hospital, et al., Case No. 3:02-cv1116(EBB). 4. Plaintiff represents that Defendant does not object to this fourteen (14) day

request for extension.

Case 3:03-cv-00149-WIG

Document 144

Filed 04/08/2005

Page 2 of 2

For the foregoing reasons, Plaintiff respectfully requests an extension of fourteen (14) days until April 22, 2005, to file replies.

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 April 8, 2005, to: Margaret J. Strange James Shea Jackson Lewis LLP 55 Farmington Ave Ste 1200 Hartford CT 06105

__________________________ Rachel M. Baird

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