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

Case 3:03-cv-00649-JBA

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Filed 05/19/2004

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UNITED STATED DISTRICT COURT DISTRICT OF CONNECTICUT VEILA VEYONNE ADAMS, ) ANTHONY L. CERRETA, ) SALVATORE SAM DIBENEDETTO, ) HOWARD DUBMAN, ) PETER FONDACO, ) GLORIA ANNETTE PEARSON JENKINS, ) BARBARA ANNE JOHNSON, ) JOSEPH A. LATTINI, ) CRESSIE M. MAYES, Individually and as ) Representative of HENRY FOSTER MAYES,) and ARTHUR J. SMITH, ) ) Plaintiffs, ) VS. ) ) TETLEY USA, INC., ) ) Defendant. )

CIVIL ACTION NO. 303 CV 649 (JBA)

MAY 19, 2004

UNOPPOSED INITIAL MOTION FOR EXTENSION OF TIME TO REPLY TO OPPOSITION TO MOTION FOR SUMMARY JUDGMENT Pursuant to Rule 6 of the Federal Rules of Civil Procedure and D. Conn. L. Civ. R. 7(b), defendant Tetley USA, Inc. ("Tetley") respectfully requests an extension of time of fourteen (14) days, to and including June 7, 2004, to respond to plaintiffs' Opposition to Motion for Summary Judgment ("Opposition") dated May 12, 2004. As grounds for this motion, Tetley states as follows: 1. Along with Attorney Tucci, the undersigned is representing the applicant in a

multi-day administrative hearing involving complex clinical and health care policy issues. The final hearing before the Connecticut Office of Health Care Access ("OHCA") is scheduled for Tuesday, May 25, 2004.

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Case 3:03-cv-00649-JBA

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2.

The undersigned also has primary responsibility for drafting the brief in an appeal

involving the administration of Medicaid benefits that is currently pending before the Connecticut Supreme Court. That brief is due on June 1, 2004. 3. Due to the foregoing scheduling conflicts, additional time is required to properly

evaluate and respond to plaintiffs' Opposition. Tetley's reply brief would otherwise be due on Monday, May 24, 2004. This is Tetley's first motion for extension of time to respond to plaintiffs' Opposition. The undersigned has conferred with plaintiffs' counsel, who consents to this motion being granted. TETLEY USA, INC.

By____________________________ Theodore J. Tucci (ct05249) [email protected] Michael J. Kolosky (ct22686) [email protected] Robinson & Cole LLP 280 Trumbull Street Hartford, CT 06103-3597 Tel. No.: (860) 275-8200 Fax No.: (860) 275-8299

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CERTIFICATION This is to certify that a copy of the foregoing was delivered by facsimile and first-class mail, postage prepaid, to the following on this 19th day of May, 2004. Steven A. Levy, Esq. Friedman, Newman, Levy, Sheehan & Carolan, P.C. One Eliot Place Fairfield, CT 06824 Alvin Green, Esq. Seham Seham Meltz & Peterson 145 E. 48th Street, Suite 5F New York, NY 10017

_________________________________ Michael J. Kolosky

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