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

Case 3:02-cv-01231-CFD

Document 92

Filed 11/24/2004

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UNITED STATES DISTRICT COURT DISTRICT OF CONNECTICUT PAULA DASHIEL, Plaintiff V. THE PRUDENTIAL INSURANCE COMPANY OF AMERICA, Defendants : : : : : : : : CIVIL ACTION NO. 3:02-cv-01231 (CFD)

NOVEMBER 23, 2004

PLAINTIFF'S MOTION FOR PERMISSION TO FILE LATE BRIEF AND ENLARGEMENT OF TIME TO FILE MEMORANDUM IN OPPOSITION TO MOTION FOR SUMMARY JUDGMENT Plaintiff, Paula Dashiel, respectfully requests pursuant to Fed. R. Civ. P. 6(b) and Local Rule 7(b), that the court grant an for permission to file late brief and enlargement of time to November 23, 2004 within which to file a Memorandum in Opposition to Defendant's Motion for Summary Judgment filed June 14, 2004. Plaintiff is unaware of defendant's position relative to this request for additional time. This is the ninth enlargement of time in this matter. Procedural Background 1. The Plaintiff commenced this action on July 17, 2002, pursuant to Title VII of

the Civil Rights Act of 1964, 42 U.S.C. 2000(e) et seq., for discrimination and disparate treatment based on her race. State common law claims were also alleged.

Case 3:02-cv-01231-CFD

Document 92

Filed 11/24/2004

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2.

This case is extremely complicated as it involves the relocation of the relocation

and real estate division of the defendant company to Phoenix, Arizona. In preparation of a response to defendant's motion for summary judgment plaintiff has been required to review substantial discovery materials involving the defendant's relocation process. This includes reviewing information relative to multiple employees from a number of facilities across the country. Further complicating the matter is the various and conflicting information obtained from the defendant at deposition and in discovery. 3. Plaintiff requires the requested enlargement in order to properly respond to the

motion for summary judgment. Defendant will not be prejudiced by this request. THE PLAINTIFF

By Michael J. Melly Fed. Bar No. 17841 Bartinik, Gianacoplos, Bartinik, Bartinik & Grater, P.C. 100 Fort Hill Road Groton, CT 06340 Tel: (860) 445-8521 Fax: (860) 445-5873

Case 3:02-cv-01231-CFD

Document 92

Filed 11/24/2004

Page 3 of 3

CERTIFICATION I hereby certify that a copy of the foregoing was mailed on November Edward Cerasia, III, Esq. Proskauer Rose, LLP One Newark Center 18th Floor Newark, NJ 07102 Jonathan B. Orleans, Esq. Zeldes, Needle & Cooper 1000 Lafayette Boulevard Bridgeport, CT 06601 ____________________________ Michael J. Melly 2004, to: