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

Case 3:00-cv-01124-WIG Document 127 Filed 09/12/2005 Page 1 of 3
. TEE UNITED STATES DISTRICT COURT
- DISTRICT OF CONNECTICUT
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DENESE EVARTS, *
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Plaintiff; *
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t v. * CIV. ACTION NO. 3:00CVl l24(WIG)
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_ ’1`I~IE SOUTI~ERN NEW *
__ ENGLAND TELEPHONE *
ff COMPANY, *
_ Defendant. * SEPTEMBER 9, 2005
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DEFEN`DAN’I"S MOTION FOR EXTENSIQN OF '{`EVIE
The defendant, the Southern New England Telephone Company, hereby requests an extension
of time through and including November 1, 2005 in order file a reply to plainti§s opposition to
motion for summary judgment. Plainti§s opposition is due for Bling on September I2, 2005.
Z` In support of this motion, the defendant states as follows:
1. On August l 1, 2005, plaintiff Eled her second Motion for Extension of Time to
file an Opposition to SNET’s Motion for Summary Judgment on or before September ll, 2005.
2. Prior to tiling said motion, plaintiH's counsel contacted the undersigned who
consented to the extension on the condition that it would also have an extension of time until early
November in order to tile e reply. The reason for the needed extension is that defense counsel knew
ORAL ARGUMENTIS NOT REQUESTED

Case 3:00-cv-01124-WIG Document 127 Filed 09/12/2005 Page 2 of 3
that she would be on trial in another matter dining most of the month of October. The plaintiffs
l requested extension would hong the repiy date into the period of time when defense eounsei would
be in {ina.! preparation for trial.
3. Piaintiits counsei fiied her Motion for Extension ot`Time to File Plaintiffs Reply with
. the above understanding.
..‘' 4. The additional time is required so that defense counsel wiii not be forced to review
i plaintiffs opposition and prepare its repiy at the same time that she is making final preparations for
triai and while on triai in another matter.
5. PlaintiH‘s counsel has indicated that she has no obj eetion to this request being granted.
WHEREFORE, the defendant respectiiilly requests an extension of time through and
I inciuding November 1, 2005 in order to tile its reply to piaintiffs Opposition to Motion for Summary
` Judgment, which is doe to be tiled with the Court on September 11, 2005.
THE DEFENDANT,
. SOUTIIERN NEW ENGLAND 'SELEPHONE
` COMPANY
""?g ri V. x
By {Fi em " ii`; éi,».~y’{‘“*’;
Lori B. Aiexander
Federai Bar No. CT 08970
TYIJER COOPER & ALCORN, LLP
205 Church Street
9 O. Box 1936
New Haven, Connecticut 06509-3910
Tei. (203) 7843200
Fax (203) 7S9—2l33
E-·Maii: aIexander(@£ty1ercooger.eom
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Case 3:00-cv-01124-WIG Document 127 Filed 09/12/2005 Page 3 of 3
CERTIFICATE GF SERVICE
Q This is to cextifir that e copy ofthe foregoing was meiied by Hrseciuss mail, postage prepaid
_. to all counsel and pro se parties of record on this 9** day of September, 2005, as follows: Karen
_ Torre, Esquire, Law Oiiices of Karen Lee Torre, 51 Him Street, Suite 307, New Haven, Connecticut
QQ 065lO.
J rf
5;:i§
Loxi B. Alexander
Federal Bar No. CT08970
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