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

Case 3:00-cv-01124-WIG

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Filed 07/11/2005

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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)

JULY 8, 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 August 10, 2005 to submit an opposition to defendant's motion for summary judgment. In support hereof, the undersigned states the following: 1. Defendant's motion dated June 21, 2005 was received by the undersigned's

office on June 22, 2005. The undersigned returned from an out of state bar convention on June 25, 2005 and reviewed the motion on Monday, June 27, 2005. 2. Plaintiff's counsel has been ill for two weeks and has missed much time from

work. It is uncertain when the undersigned will be fully recovered. 3. Defendant's voluminous submission is obviously the product of much work

over an extended time by defense counsel. The preparation of the opposition will be very

Case 3:00-cv-01124-WIG

Document 121

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time-consuming and will require review of thousands of pages of deposition transcripts and exhibits and much legal research. 4. Plaintiff's counsel is presently under obligation to complete a Joint Trial

Memorandum and associated pleadings and briefs due to the Hon. Mark R. Kravitz in connection with a employment case which is proceeding to trial in August. The undersigned is a sole practitioner and is responsible for handling these obligations. 5. In compliance with Local Rule, the undersigned represents that this is the first

enlargement sought. In addition, the undersigned office telephoned defense counsel regarding this motion but defense position could not be ascertained as counsel was unavailable. WHEREFORE, the undersigned counsel respectfully requests this motion be granted.

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Case 3:00-cv-01124-WIG

Document 121

Filed 07/11/2005

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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 July 8, 2005, to: Lori Alexander, Esq. Tyler, Cooper & Alcorn 205 Church Street New Haven, CT 06509

________________________________ Karen Lee Torre

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