Free Motion for Extension of Time - District Court of Connecticut - Connecticut

Case 3:00-cv-00052-RNC

Document 70

Filed 11/10/2004

Page 1 of 2

UNITED STATES DISTRICT COURT DISTRICT OF CONNECTICUT MARGARET COWAN, ADMINISTRATRIX OF THE ESTATE OF VICTORIA COOPER v. MICHAEL BREEN : : : : : : :

NO.: 3:00 CV 0052 (DJS)

MARGARET COWAN, ADMINISTRATRIX OF THE ESTATE OF VICTORIA COOPER v. NORTH BRANFORD

: : : : : : :

NO.: 3:01 CV 0229 (DJS)

NOVEMBER 10, 2004

JOINT MOTION FOR ENLARGEMENT OF TIME TO FILE JOINT TRIAL MEMORANDUM NUNC PRO TUNC

Pursuant to Local Rule 9(b)1(a), the defendants, MICHAEL BREEN and TOWN OF NORTH BRANFORD, hereby move the Court for an enlargement of time of thirty (30) days, up to and including November 30, 2004, in which to file the joint trial memorandum in this case. The undersigned counsel has contacted counsel for the plaintiff, Attorney David N. Rosen, and Attorney Rosen has no objection to the granting of this motion. In support of this Motion, the defendants offer as follows: 1. While this Motion requests additional time in which to complete these tasks, the parties submit that the additional time will lead to the just, inexpensive and efficient administration of justice.

Case 3:00-cv-00052-RNC

Document 70

Filed 11/10/2004

Page 2 of 2

2. 3.

Coordinating the schedule of the parties' counsel has been difficult. The joint trial memorandum is nearly complete and counsel expects to file it before November 30, 2004, but desire the additional time to be sure everything is complete.

WHEREFORE, the parties request that their Motion for Enlargement of Time, up to and including November 30, 2004, be granted.

THE DEFENDANTS, MICHAEL BREEN and TOWN OF NORTH BRANFORD

/s/John J. Radshaw, III Thomas R. Gerarde, ct5640 John J. Radshaw, III, ct19882 HOWD & LUDORF 65 Wethersfield Avenue Hartford, CT 06114 (860) 249-1361 (860) 249-7665 (fax)

CERTIFICATION This is to certify that a copy of the foregoing has been sent, handling charges prepaid, via U.S. Mail to the following counsel of record this 10th day of November, 2004 David N. Rosen, Esquire Rosen & Dolan, PC 400 Orange Street New Haven, CT 06511

/s/John J. Radshaw, III Thomas R. Gerarde John J. Radshaw, III

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