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

Case 3:02-cv-02130-AWT

Document 67

Filed 04/17/2007

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UNITED STATES DISTRICT COURT FOR THE DISTRICT OF CONNECTICUT

FAIR HAVEN DEVELOPMENT CORPORATION Plaintiff V. JOHN DESTEFANO, ET AL. Defendants

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NO. 3:02CV02130 (AWT)

APRIL 17, 2007

DEFENDANTS' MOTION FOR EXTENSION OF TIME IN WHICH TO REPLY TO PLAINTIFF'S MEMORANDUM OF LAW IN OPPOSITION TO DEFENDANTS' MOTION FOR SUMMARY JUDGMENT Defendants, pursuant to Fed. R. Civ. P. 7(b), request an extension of time of up to and including April 30, 2007, to respond to plaintiff's memorandum of law in opposition to defendants' motion for summary judgment. Undersigned counsel and

Attorney Audrey Kramer are presently representing the defendants in this matter. Unfortunately, both counsel have undergone hospitalization and surgical procedures for medical conditions during the past three weeks that has caused both of us to be absent from the office for over a week in each instance, and Attorney Kramer is still not back at work on a full time basis. Additionally, the Office of Corporation Counsel is operating with a reduced number of attorneys in the litigation section due to the continuing difficulty in replacing a litigation attorney who left this office in January, 2007. As a result of the above, undersigned counsel and Attorney Kramer have not yet had ORAL ARUGUMENT NOT REQUESTED

Case 3:02-cv-02130-AWT

Document 67

Filed 04/17/2007

Page 2 of 3

sufficient time to review the opposition filing of the plaintiff and the documents that the plaintiff has submitted. In accordance with D. Conn. L. Civ. R. 7(b), the undersigned represents that Attorney Kramer spoke with plaintiff's attorney, Katrena Engstrom on April 16, 2007, and Attorney Engstrom told Attorney Kramer that she did not object to this extension of time. This is defendants' first request for an extension of time to respond to plaintiff's memorandum of law in opposition to defendants' motion for summary judgment. THE DEFENDANTS,

BY:_/s/_____________________________ Michael A. Wolak, III Assistant Corporation Counsel City of New Haven Office of Corporation Counsel 165 Church Street New Haven, CT 06510 (203) 946-7970 Fax: (203) 946-7942 E-mail: [email protected] Fed. Bar #ct12681 Their Attorney

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Case 3:02-cv-02130-AWT

Document 67

Filed 04/17/2007

Page 3 of 3

CERTIFICATION This is to certify that a copy of the foregoing was delivered electronically and/or mailed, postage prepaid, on April 17, 2007, to the following counsel of record: Katrena Engstrom, Esq. John R. Williams, Esq. John R. Williams & Associates, LLC 51 Elm Street, Suite 409 New Haven, CT 06510 /s/:_____________________________ Michael A. Wolak, III

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