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

Case 3:01-cv-01828-CFD

Document 72

Filed 07/12/2004

Page 1 of 2

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF CONNECTICUT __________________________________________x CAROL PERRY, : Plaintiff, : v. : : DOCTOR'S ASSOCIATES INC., : Defendant. : __________________________________________x CIVIL ACTION NO. 3:01 CV 1828 (CFD)

JULY 8, 2004

MOTION FOR EXTENSION OF TIME Pursuant to Rule 7(b) of the Local Rules of Civil Procedure of the United States District Court for the District of Connecticut, plaintiff respectfully requests an eleven day extension of time for filing her opposition to Defendant's Motion to Compel dated June 16, 2004 up to and including Monday July 19, 2004. This is plaintiff's first request for an extension of this deadline. In support of this request, undersigned counsel represents that Attorney Christine Caulfield, who together with Attorney Kathryn Emmett represents plaintiff in this action, is away from the office on a family vacation and not able to complete the preparation of plaintiff's opposition to defendant's motion to compel to file by today's filing deadline. In addition, Attorney Kathryn Emmett is also unable to complete plaintiff's opposition due to scheduling conflicts involving court appearances and depositions in a number of cases, including Jane Doe v. Derma Clinic, et al, Docket Number CV 01 0382381S; Holly Allen v. Joseph Burden, et al, Docket Number CV 01 0384425S; Mary Roe v. Joseph Burden, et al, Docket Number CV 02 0396666S; State of Connecticut v. David Levi, Docket Number CR 03 100768S; Brian Clark

Case 3:01-cv-01828-CFD

Document 72

Filed 07/12/2004

Page 2 of 2

v. Vermont Pure Holdings, Ltd., et al, Docket Number 3:02 CV 2278 (MRK); and Heidi E. Schroeder v. ACMI Corporation, et al, Docket Number 3:03 CV 0410 (MRK). Undersigned counsel has contacted Attorney Kristin Corcoran, who represents the defendant in this action, to ascertain whether defendant objects to this request and she has indicated that defendant does not object to this request for an extension of time. This action has not been assigned for trial. THE PLAINTIFF CAROL PERRY,

BY: KATHRYN EMMETT Emmett & Glander 45 Franklin Street Stamford, CT 06901 (203) 324-7744 Federal Bar No. ct05605 Email: [email protected] CERTIFICATION This is to certify that a copy of the foregoing was mailed, postage prepaid, this 8th day of July, 2004, to: Kristin Corcoran, Esq. Doctor's Associates Inc. 325 Bic Drive Milford, CT 06460.3059

Kathryn Emmett -2-