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

Case 3:00-cv-01124-WIG

Document 125

Filed 09/12/2005

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UNITED STATES DISTRICT COURT DISTRICT OF CONNECTICUT DENISE EVARTS Plaintiff V. THE SOUTHERN NEW ENGLAND TELEPHONE COMPANY, Defendant : : : : : : : : :

Civil No. 3:00CV1124 (WIG)

SEPTEMBER 9, 2005

MOTION FOR ENLARGEMENT OF TIME TO RESPOND TO DEFENDANT'S MOTION FOR SUMMARY JUDGMENT The undersigned counsel for the plaintiff respectfully moves this Court for an enlargement of time of seven (7) days or to Monday, September 19, 2005 to submit an opposition to defendant's motion for summary judgment. Defense counsel was contacted and has no objection to the granting of this motion. In support of this motion, the undersigned states the following: 1. The undersigned has performed a substantial amount of work on the opposition

already. The preparation of it required the review of thousands of pages of documents and deposition transcripts. Ten depositions were taken in this case, three of them involving multiple examinations on different dates. 2. The undersigned has gotten through all of this material and is in the process of

getting the exhibits bound and finalizing the plaintiff's statement of facts. What remains to be

Case 3:00-cv-01124-WIG

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prepared is the Memorandum of Law which the undersigned needs the additional week to write. 3. The undersigned's time of late has been largely consumed by obligations in two

other pending civil cases assigned to the Hon. Mark R. Kravitz. As was stated in the previous motion for enlargement, the undersigned was involved in trial proceedings before Judge Kravitz in the matter of Lorusso v. Borer, Docket No. 3:03CV00504 (MRK). Highly unusual post-judgment issues have arisen in that case which have taken a great deal of the undersigned's time and continue to do so. In addition, in Ricci v. DeStefano, Docket No. 3:04CV01109 (MRK), the undersigned was ordered by Judge Kravitz to complete discovery and take four depositions, all of which are being conducted in a very tight time frame. Two of the depositions have been taken in the past week and a half and the other two are to take place shortly. In between these depositions, there is ongoing document disclosure obligations among counsel. For the foregoing reasons, an additional one week enlargement has become necessary to prepare the opposition in this case. The undersigned represents that there were two previous extensions sought in this case.

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Case 3:00-cv-01124-WIG

Document 125

Filed 09/12/2005

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Respectfully submitted: THE PLAINTIFF, DENISE EVARTS

BY:________________________ KAREN LEE TORRE Federal Bar No. ct01707 Law Offices of Karen Lee Torre 51 Elm Street Suite 307 New Haven, CT 06510 (203) 865-5541 Her Attorney

CERTIFICATION I hereby certify that a copy of the foregoing was mailed, First Class, postage paid, on September 9, 2005, to: Lori Alexander, Esq. Tyler, Cooper & Alcorn 205 Church Street New Haven, CT 06509 ________________________________ Karen Lee Torre

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