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

Case 3:03-cv-00149-WIG Document 138 Filed O3/21/2005 Page 1 of 3
UNITED STATES DISTRICT COURT
for the
DISTRICT OF CONNECTICUT
FERRON SHORTER JR,
Plaintiff, :
: CIVIL NO: 303 CV Oi49(WIG)
v, :
HARTFORD FINANCIAL SERVICES GROUP,
INCI and MARYANNE RHODES :
Defendants. : MARCI-I 18, 2005
DEFENDANTS MOTION TO EXTEND TIME TO RESPOND TO PLAINTIFF’S
MOTION F OR EQUITABLE RELIEF
Pursuant to Local Rule 7(b) of this Court, Hartford Financial Services Group, Inc,
(“DC`I`B1}CIE11Il”) respectfully requests an extension of time of eight (8) clays to file its
Meinorandunr in Opposition to PlaintifI" s Motion for Equitable Relief dated Febrriary 28, 2005.
In support oftliis motion, Defendant states:
i, On February 28, 2005, Plaintiff` tiled his Motion for Equitable Relief in
which Plaintiff seeks reiristaternent or an award of trout pay, as well as an award of pregjudgrnent
and postqiucigment interest,
2. DCIl31'tGlE11l€iS response to Plaintil”l”s Motion for Equitable Relief is due
March 2l, 2005,
.3, Defendant requests additional time to respond to Plairitiffs Motion for
Equitable Relief to allow sufficient time for Defendant to research the legal issues raised by
ORAL ARGUMENT NOT REQUESTED

Case 3:03-cv-00149-WIG Document 138 Filed O3/21/2005 Page 2 of 3
Plaintiff and to evaluate the lengthy affidavit and extensive financial information submitted by
Plaintiff in support of his inotioni
4. Defendant seeks only an additional eight days to respond to Plaintiffs
Motion for Equitable Relief and the requested extension of time will not unduly delay this
niatter.
5. The undersigned counsel contacted counsel for Plaintiff, Attorney Baird,
who has no objection to the granting of this motion,
WHEREFORE, Defendant respectfully moves for an eight (8) day extension of
time until March 29, 2005 to tile its l\/leinoiandtini in Opposition to Plaintiff` s Motion for
Equitable Reliefdated Febrtia1·y 28, 2005.
DEFENDANT,
HARTFORD FINANCIAL SERVICES
GROUP, INC,
‘ Gmwi: *
By: A _ .
l set J, Strange (ct082l.?.)
Ja t. Shea (ctl6'/50)
Jackson Lewis LLP
55 Farmington Avenue, Suite 1200
Hartford, CT 06lO5
(860) 522-0404
email: SlFH1}gC1H@lE1Ci{SOlll€WlSi.COlll
email: slieaj @jacl 2

Case 3:03-cv-00149-WIG Document 138 Filed O3/21/2005 Page 3 of 3
CERTIFICATION OF SERVICE
This is to certify that a copy of the foregoing was sent via Iirst class mail, postage
prepaid, on this l8th day of March 2005, to the following counsel of record:
Rachel M. Baird
Law Office of Rachel M, Baird
379 Prospect Street
Torrington, CT 06790
Attorney for Plaintiff
David L. Metzger
Metzger & Associates
25 Capitol Avenue
Hartford, CT 061064707
Attorney for Defendant Maryanne Rhodes
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