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

Case 3:02-cv-01231-CFD

Document 91

Filed 11/15/2004

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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 13, 2004

PLAINTIFF'S MOTION FOR 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 enlargement of time to November 19, 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 eighth 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. 2. Counsel for Plaintiff has recently been required to work on other legal

Case 3:02-cv-01231-CFD

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matters including: Counsel for the plaintiff has recently been busy on legal work involving other maters, including: Dashiel v. Prudential Insurance Company of America, 3:02 cv 01231 (CFD) [Memorandum in Opposition to Motion for Summary Judgment]; Richard Hamilton v. AMTRAK, [union grievance hearing]; Richards v. Computer Sciences Corporation [class action] 3:03 cv 630 (DJS); Counsel for the parties have been working out some discovery that the plaintiff claims was not provided; On November 10, 2004 the defendant provided discovery responses to the plaintiff. A brief amount of additional time is needed to digest the information and discuss it with the plaintiff. 3. 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. 4. Plaintiff requires the requested enlargement in order to properly respond to the

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

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Plaintiff, Paula Dashiel

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

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

Case 3:02-cv-01231-CFD

Document 91

Filed 11/15/2004

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