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

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Case 3:03-cv-OO712-WMVE Document 23 Filed O1/05/2004 Page 1 of 3
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UNITED STATES DISTRICT COURT {J [_ _
DISTRICT OF CONNECTICUT ZUUH Ml ·~ .;> A l0· 0 8 {
GERTRUDE BAYONNE, : A A g
Plaintiff,
: Civ. Action N0.
3:03CV0712(WWE)
v. :
PITNEY BOWES, INC., : I
Defendant. DECEMBER 31, 2003
PLAINTIFFS’ MOTION FOR EXTENSION OF TIME TO FILE
MEMORANDUM OF LAW IN RESPONSE TO
DEFENDANTS’ OPPOSITION TO PLAINTIFF’S MOTION TO FILE A
REVISED AMENDED COMPLAINT I
On December 22, 2003, Plaintiff filed a Motion for Extension of Time to respond
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to Defendant’s Objection to Plaintiffs Motion to Amend the Complaint. The caption of l
the pleading was incorrectly labeled as a “1T1€1T101`E11'1ClLl1'1] of law" and should have read
"Motion for Extension of 'l`ime". Plaintiff now files a corrected pleading.
Plaintiff Gertrude Bayonne hereby respectfully requests an extension of time to
Hle a Memorandum of Law in Opposition to the Defendants’ Opposition to Plaintiff’ s
Motion to File a Revised Amended Complaint dated December 9, 2003, pursuant to
Local Civil Rule 9(b). Plaintiff requests an additional fifteen (15) days from the date the
original responsive pleading was due to be filed, December 22, 2003. The proposed new
ORAL ARGUMENT NOT REQUESTED A
TESTIMONY NOT REQUIRED 5


Case 3:03-cv-00712-\/QWE Document 23 Filed O1/05/2094 Page 2 of 3 i
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deadline for filing Plaintiffs memorandum of law in opposition will be up to and
including January 5, 2004.
Plaintiff asserts that good cause exists for granting the instant motion: l)
Plaintift”s counsel needs additional time to prepare a responsive pleading; and 2) the
undersigned has previously scheduled a vacation time during the holiday season.
Counsel for Plaintiff contacted counsel tor the Defendant on December 19, 2003,
who consented to the instant motion.
This is Plaintiff’s first request for an extension of time to {ile a responsive
pleading to the Defendants’ Opposition to Plaintiff’ s Motion to File a Revised Amended
Complaint.
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Dated: Southport, CT PLAINTIFP,
December 31, 2003 GERT DE BAYONNE
By: .` - in
Mark P. Carey (ctl 8)
Carey & Associates, P.C.
Attorneys At Law
71 Old Post Road, Suite One
Southport, CT 06490
(203) 255-4150 tel.
(203) 255-0380 fax.
[email protected]
Attorney for Plaintiff
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i n Case 3:03-cv-OO712-WE Document 23 Filed O1/05/3504 Page 3 of 3 [
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CERTIFICATE OF SERVICE I
THIS IS TO CERTIFY, that the toregoing was delivered via UPS Next Day I
Service, fee prepaid, this the 31st day of December, 2003 to: I
Mare L. Zakeh
Edwards & Angell, LLC
Three Stamford Plaza
301 Tresser Boulevard A
Stamtbrd, CT 06901 p
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Mark P. Carey
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