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

Case 3:00-cv-01124-WIG

Document 123

Filed 08/11/2005

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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)

AUGUST 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 thirty (30) days or to September 11, 2005 to submit an opposition to defendant's motion for summary judgment. In support hereof, the undersigned states the following: 1. Plaintiff's counsel was ill for one month resulting in her absence most of the

month of July from her office. During this same time the undersigned was under the obligation to prepare a Joint Trial Memorandum and associated pleadings and briefs due to the Hon. Mark R. Kravitz in connection with an employment case which proceeded to trial on August 2, 2005. The undersigned is still on trial in that case before Judge Kravitz. The undersigned is a sole practitioner and is responsible for handling these obligations. 2. In compliance with Local Rule, the undersigned represents that this is the second

Case 3:00-cv-01124-WIG

Document 123

Filed 08/11/2005

Page 2 of 2

enlargement sought. In addition, the undersigned's office telephoned defense counsel regarding this motion who indicated she has no objection to the granting of this motion. WHEREFORE, the undersigned counsel respectfully requests this motion be granted. 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 August 9, 2005, to: Lori Alexander, Esq. Tyler, Cooper & Alcorn 205 Church Street New Haven, CT 06509 ________________________________ Karen Lee Torre

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