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

I se 3:03-cv-00666-AWT Document 19 Filed O2/27/2004 Page 1 of 2
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UNITED STATES DISTRICT COURT
DISTRICT OF CONNECTICUT? I E I gr- E II;
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LINDA sruRM, ; CIVIL ACTIONPINOI i»ii‘iii= Y it I
Plaintiff, I s;0sC\/0666 (AwT)
V.
ROCKY HILL BOARD OF EDUCATION I I
; FEBRUARY 26, 2004 I
Defendant. :
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PLAINTIFF’s UNOPPOSED MOTION FOR A TWO-WEEK EXTENSION TO RESPOND T0 .
THE DEFENDANT’S MOTION T0 DISMISS I
The plaintiff, Linda Sturm, moves to extend the deadline to respond t0 the defendants I
Motion to Dismiss from February 25, 2004 to March 10, 2004. This is the plaintiffs first request I
for an extension of the deadline to respond. Defendant’s counsel, Martha Shaw, represented E
that the defendant does not oppose the pIaintiff's motion for a two-week extension.
The plaintiff requests an extension because Tanya Woianic, the associate who had been
primarily handling the case, left the firm to accept a position with the law firm of Jackson Lewis
and started in her new position on February 2, 2004. Although the undersigned counsel has
hired a new associate, Tammy I\/larzigliano, who started on February 19, 2004, she has been
unable to complete the brief in opposition to the defendant’s motion, while simultaneously taking
over Attorney WoIanic's entire case load.
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% .. -, se 3:03-cv-00666-AWT Document 19 Filed O2/27/2004 Page 2 of 2 i
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THE PLAINTIFF, ,
LINDA STURM %
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Gary Phel (CT 03670) I
Gary Phelan, L.L.C.
433 South Main Street, Suite 117 `
, West Hartford, CT 06110 `
I (860) 313-5005
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é QERTIFICATE OF SERVICE
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I certify that a copy of the foregoing was mailed, first-class, postage prepaid, on February
If 26, 2004 te:
W Martha Shaw
T Michael J. Rose
_ Eric D. Eddy
{ Howd & Ludorf
` 65 Wethersfield Avenue
Hartford, CT 06114
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I Gary Phgan
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