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

i ” Case 3:02-cv-0219?;_l\/IRK Document 23 Filed 02/1 @2004 Page 1 0 3
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H UNITED STATES DISTRICT 0 . 4- -.: s. l
y DISTRICT or CONNECTICU L P 0 e-0- l 0
RICHARD v. ROBINSON : crvu,. ACTION No.
vs. : 3:02CV2l97 (MRK) ‘
i CITY OF HARTFORD and
ALBERT G. nic ; FEBRUARY 9, 2004
MOTION EoR EXTENSION on TIME WITHIN wnrcn TO RES · • ND
TO DEFENDANT’S MOTION FOR SUMMARY JUDGMENT
The plaintiff, RICHARD V. ROBINSON, by counsel, pursuant to Local Rul s 'I•'(b), hereby
moves this Honorable Court for a 30 day extension of time within which to respondto the Defenda.nt’s I
Motion for Summary Judgment, that is an extension until March 23, 2004.
In support of said Motion, counsel represents as follows: i
1. There have been no prior requests for an extension of time with respe t to this
particular time limitation;
2. The plaintiff, Richard V. Robinson, is currently on a job assignment i Bosnia and, l
therefore, not immediately available to plaintiff s counsel, thus necessitating adclitiona time to prepare
for a response to the Motion for Summary Judgment; I
3. The complexity of the issues raised by the Motion for Summary Jud ; 0 ent requires
additional time for counsel to adequately prepare a responsive pleading.
The undersigned counsel has communicated with counsel for the defendant w o has indicated
that she has no objection to the granting of this motion.
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Case 3:02-cv-0219/7-5/IRK Document 23 Filed 02/1, 2004 Page 2 •» 3
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Dated at Hartford, Connecticut on this 9th day of February, 2004.
PLMNTIFF,
RIC ¤.:._ ·•:|.a·» _
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By ·¤< 1 1
M. Hatcher Norris, Esq. - `V
BUTLER NORRIS & Gow 1
254 Prospect Avenue
Hartford, CT 06106
T61. N6. (860) 236-6951 ~
Federal Bar No. ct 00061 1
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Case 3:02-cv-O21S{»7—§/IRK Document 23 Filed O2/1&%OO4 Page 3 •» 3
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CERTIFICATION
I hereby certify that a copy of the foregoing was mailed postage prepaid, via 1rst-class mail on \
this 9th day of February, 2004 to: p
Attomey Helen Apostolidis 1
Assistant Corporation Counsel 1
550 Main Street 1
Hartford, CT 06103 I
The Honorable Mark R. Kravitz I
United States District Court
District of Connecticut
141 Church Street {
New Haven, CT 06510
(CHAMBERS COPY) G ,, 1
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M. Hatcher Norris, Esq.
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