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

Case 3:02-cv-02006-WWE

Document 40

Filed 03/23/2005

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UNITED STATES DISTRICT COURT DISTRICT OF CONNECTICUT
CENTERFOLDS, INC. and MARIO PIROZZOLI, JR., Plaintiffs VS. TOWN OF BERLIN, BONNIE L. THERRIEN, IDA RAGAZZI, JOANNE G. WARD, JOSEPH ARESIMOWICZ, and LINDA CIMADON, Defendants : : : CIVIL NO. 3:CV02006 (WWE) : : : : MARCH 18, 2005

SECOND REQUEST FOR MOTION FOR EXTENSION OF TIME TO FILE SUMMARY JUDGMENT AS TO ADDITIONAL CHALLENGES TO THE ORDINANCE The plaintiffs request a thirty day extension, including and up to March 21, 2005, to file their motion for summary judgment. The plaintiffs represent the following: 1. On December 20, 2005, this Court filed its ruling on the defendants' motion for summary judgment. 2. In the Court's ruling, the Court requested that if the plaintiff chose to file a motion for summary judgment it must be filed with the Court by February 18, 2005. 3. Plaintiff's counsel requested and received an extension of time, until March 21, 2005, to file its summary judgment. 4. Counsel for both parties have been in negotiations regarding several

Case 3:02-cv-02006-WWE

Document 40

Filed 03/23/2005

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outstanding issues and have not completed their negotiations. 5. Plaintiff's counsel recently provided defendant counsel with a demand for settlement, to which the defendant has not responded. 6. Plaintiff does not want to lose the right to file the motion for summary judgment in the event negotiations do not succeed. 7. This is the plaintiffs's second request for an extension to file a motion for summary judgement. 8. Plaintiff's counsel was unable to reach defendants' counsel to determine if counsel agreed with plaintiff's request.

THE PLAINTIFFS

BY___________________________ Kim Coleman Waisonovitz Federal Bar No. ct25759 Law Offices of Norman A. Pattis LLC 649 Amity Road, P.O. Box 280 Bethany, CT 06524 Telephone (203) 393-3017 Their Attorney

Case 3:02-cv-02006-WWE

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Filed 03/23/2005

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CERTIFICATION

This is to certify that a copy of the foregoing was mailed, first class mail, postage prepaid, on March 18, 2005, to the following counsel of record: Thomas R. Gerard, Esq. Howd & Ludorf 65 Wethersfield Avenue Hartford, CT 06114

________________________ Kim Coleman Waisonovitz