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

i .. Case 3:00-cv-O1124-W|GODocument 128 Filed O9/20/2005 Page 1 of 2 Omni
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UNITED STATES DISTRICT COURT
DISTRICT OF CONNECTICUT
DENISE EVARTS :
Plaintiff
V Civil N0. 3:00CV1124 (WIG)
THE SOUTHERN NEW :
ENGLAND TELEPHONE COMPANY, : SEPTEMBER 19, 2005
Defendant
MOTION FOR ONE DAY EXTENSION OF TIME
NUNC PRO TUNC
The undersigned counsel moves, nunc pro tunc, for a one day enlargement of time to
file Plaintiffs Opposition to Defendants Motion for Summary Judgment. In support of this
motion, the undersigned represents that due to a crash of the database in the undersigned’s
office network, a consequence of which was the permanent loss of an entire section of the
undersigned’s brief. This necessitated a duplication of the work already performed. Due to
this unexpected occurrence, the undersigned could not prepare a timely motion. The
undersigned’s office contacted defense counsel in this case and was advised that defense
counsel has no objection to the extension of time.
The undersigned represents that three (3) previous extensions were sought and
Wl—lEREFORESthei Lgptlqygigtmdgimgunsel respectfully requests that this motion be
granted. G Q mg








. · * Case 3:00-cv-O1124-WIC}-~~UDocument 128 Filed O9/20/2005* Page 2 of 2
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Respectfully submitted:
THE PLAINTIFF, DENISE EVARTS .
BY· l
égni-an LEE-TORRE l
_ Federal Bar No. ctO1707
Law Offices of Karen Lee Torre i
51 Elm Street, Suite 307
New Haven, CT 06510
(203) 865-5541
Her Attorney
CERTlFICATlON
I hereby certify that a copy of the foregoing was mailed, FirstClass, postage paid,
on September 19, 2005, to:
Lori B. Alexander, Esq.
Tyler, Cooper & Alcorn, LLP l
205 Church Street
New Haven, CT 06509
Q % i l
Ka Lee Torre
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