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

Case 3:03-cv-00712-WWE Document 57 Filed 06/16/2004 Page 1 of 3
UNITED STATES DISTRICT COURT
DISTRICT OF CONNECTICUT
GERTRUDE BAYONNE, :
Plaintiff,
: Civ. Action No.
3:03C\/0712(WWE) "
v. :
PITNEY BOWES, INC. & : i
THE PITNEY BOWES, INC.
LONG TERM DISABILITY PLAN, : ’
THE PITNEY BOWES, INC. LONG
TERM DISABILITY PLAN :
ADMINISTRATOR AND THE
PITNEY BOWES, INC. :
DISABILITY DEPARTMENT`, We
Defendants. : JUNE 15, 2004
PLAINTIFFS’ MOTION FOR EXTENSION
OF TIME TO FILE AN OPPOSITION TO DEFENDANTS’ CROSS ;
MOTION FOR. SUMMARY JUDGMENT AND DEFENDANTS DEADLINE TO
FILE REPLY BRIEF
l
Plaintiff Gertrude Bayonne hereby respectfully requests an extension of time to
file an opposition to Defendants’ Cross Motion for Summary Judgment, pursuant to
Local Rule 9. Defendants filed a Cross Motion for Summary Judgment on May 28, 2004 0
and served by mail on that date. The original deadline to file Plaintiffs Opposition Brief
is June 2l, 2004. Plaintiff respectfully requests a twenty-one day (2l) extension of time
until July I2, 2004 to tile her Memorandum in Opposition.
ORAL ARGUMENT NOT REQUESTED
TESTIMONY NOT REQUIRED

Case 3:03-cv-00712-WWE Document 57 Filed 06/16/2004 Page 2 of 3
Plaintiff asserts good cause exists for granting the instant motion. Plaintiff asserts _
the following: (1) the undersigned requires additional time to review the facts and legal
arguments set forth in Defendants Cross Motion for Summary Judgment; (2) the
undersigned is required to file a Motion for Summary Judgment in an unrelated case
(Boehm v. Cornell University LTD Plan etal., 04 CTV 091l(WHP)(S.D.N.Y.)) by June
30, 2004; (3) the undersigned has been preparing an Opposition Memorandum of Law to
a Cross Motion for Summary Judgment in an unrelated ease (Milde v. Town of
Greenwich Housing Authority. etal., 3:00CV2423(AVC)(D.Conn.), which was filed on
June 14, 2004.
Plaintiff has contacted counsel for the Defendants on this date, who consented to
the instant motion.
Defendants have also requested permission to file their Reply Briefon July 26, st.
2004, which is still within the Local Rule 9(g) time limits. Plaintiff has consent to O
Defendants’ request.
PLAJNTJPP,
GERT ' U E BAYONNE I,
BY;. rr K Gt. , J
Mark P. cai szsi
Carey & Associa es, P.C.
Attorneys At Law
71 Old Post Road, Suite One
Southport, CT 06490
(203) 255-4150 tel.
(203) 255-0380 fax.
1\/[email protected]
Her Attorney
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{ Case 3:03-cv-00712-WWE Document 57 Filed 06/16/2004 Page 3 of 3
CERTIFICATE OF SERVICE i
THIS IS TO CERTIPY, that the foregoing was delivered via first class mail,
postage prepaid, this the l5m day of I une, 2004 to:
Theodore J. Tucci
Robinson & Cole, LLP
280 Trumbull Street
Hartford, CT 06103 ”
Nicole A. Diller
Sonnenschein, Nath & Rosenthal, LLP
685 Market Street, 6m Floor
San Francisco, CA 94105
Attorneys for Defendants I
— l6i ”
ark P. Carey T W
l
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