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

Case 3:00-cv-02005-AHN

Document 52

Filed 12/01/2003

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UNITED STATES DISTRICT COURT DISTRICT OF CONNECTICUT

SUSAN NG-VECCHI, Plaintiff, v. JOHN W. SNOW, SECRETARY OF THE TREASURY, in his official capacity, Defendant.

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CIVIL NO.

3:00CV2005(AHN)

November 26, 2003

MOTION TO ENLARGE TIME TO FILE DISPOSITIVE MOTION The defendant, with consent of counsel for plaintiff, hereby requests an enlargement of time until December 22, 2003, to file a dispositive motion for summary judgment and/or dismissal of all counts of the complaint in this matter. By endorsement order on March 28, 2003, the Court approved the parties' request to extend the deadline for the filing of dispositive motions until 30 days after the conclusion of settlement negotiations with Magistrate Judge Fitzsimmons. See Dkt # 39. On October 27, 2003, the Court held a pretrial conference regarding the defendant's offer of judgment dated September 30, 2003, and whether plaintiff would accept the offer. Counsel for

plaintiff, Attorney John Williams, requested additional time to consult with plaintiff which was granted by the Court.

Case 3:00-cv-02005-AHN

Document 52

Filed 12/01/2003

Page 2 of 3

Attorney Williams recently informed the undersigned that plaintiff has again rejected the offer of judgment by the defendant and that this case could not be settled. Accordingly, it appears that the extensive settlement negotiations over the past few months have not been successful in resolving this matter and the litigation of this case should now proceed forward. To that end, the undersigned requests that the dispositive motion deadline be reset for December 22, 2003. plaintiff has no objection. Respectfully submitted, DEFENDANT, JOHN W. SNOW, SECRETARY OF THE TREASURY KEVIN J. O'CONNOR UNITED STATES ATTORNEY WILLIAM M. BROWN, JR. ASSISTANT U.S. ATTORNEY 157 CHURCH STREET P.O. BOX 1824 NEW HAVEN, CT 06508 (203) 821-3700 (203) 773-5373 - FAX FEDERAL BAR NO. ct20813 Counsel for

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Case 3:00-cv-02005-AHN

Document 52

Filed 12/01/2003

Page 3 of 3

CERTIFICATION OF SERVICE This is to certify that a copy of the within and foregoing was sent by first class mail on this 26th day of November, 2003, to: John R. Williams, Esq. Williams & Pattis 51 Elm St. New Haven, CT 06510 WILLIAM M. BROWN, JR. ASSISTANT UNITED STATES ATTORNEY

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