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

Case 2:91-cv-00180-RNC

Document 487

Filed 11/22/2004

Page 1 of 3

UNITED STATES DISTRICT COURT DISTRICT OF CONNECTICUT

P.J., et al., Plaintiffs, v. STATE OF CONNECTICUT, et al. Defendants.

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CIVIL NO. 291CV00180 (RNC)

NOVEMBER 19, 2004

MOTION FOR ENLARGEMENT OF TIME

The plaintiffs move for a ten day enlargement of the time to file a Reply to the defendants' Memorandum in Opposition to Plaintiffs' Motion for Further Attorneys' Fees and Costs. In support of this Motion the plaintiffs represent the following: 1. The plaintiffs' Motion for Attorneys' Fees and Costs was filed on October 4, 2004. [Doc. ## 482, 483.] 2. Defendants' Memorandum in Opposition to the Motion for Attorneys' Fees and Costs was filed on November 17, 2004 [Doc. #485]. 3. Under Local Rule 7(d) plaintiffs' Reply brief is due on December 1, 2004. 4. Plaintiffs are unable to file their Reply by December 1, 2004 due to plaintiffs' counsel's vacation during the week beginning November 22, 2004 and briefs that are due in B.H. v. Southington Board of Education, No. 3:02CV252 (SRU) during that same period of time.

Case 2:91-cv-00180-RNC

Document 487

Filed 11/22/2004

Page 2 of 3

5. Despite good faith attempts, plaintiffs were unable to ascertain the position of opposing counsel, Ralph Urban, Esq., as to this request. 6. This is the first motion for enlargement of time filed with respect to this time limitation. WHEREFORE, the plaintiffs request a ten day enlargement of the time within which their Reply brief is due such that their brief will be due on December 13, 2004.

PLAINTIFFS,

By /s/ David C. Shaw David C. Shaw, Esq. Fed. Bar No. ct05239 34 Jerome Ave., Suite 210 Bloomfield, CT 06002 (860) 242-1238 Email [email protected]

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Case 2:91-cv-00180-RNC

Document 487

Filed 11/22/2004

Page 3 of 3

CERTIFICATION This is to certify that a copy of the foregoing was mailed first class, postage prepaid to all counsel of record on November 19, 2004. Ralph E. Urban, Esq. Assistant Attorney General State of Connecticut P.O. Box 120 Hartford, CT 06141 Frank J. Laski, Esq. Mental Health Legal Advisors 294 Washington St., Suite 320 Boston, MA 02108

/s/ David C. Shaw David C. Shaw, Esq.

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