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

Case 3:03-cv-00623-CFD Document 35 Filed 07/23/2004 Page 1 of 3
UNITED STATES DISTRICT COURT
DISTRICT OF CONNECTICUT
KAREN HARTER, )
Plaintiff, 3 CIVIL ACTION NO.
) 3:03CV623 (CFD)
v. )
)
US INV ESTIGATIONS SERVICES, INC., )
Defendant. I July 23, 2004
DEFENDANT'S FOURTH MOTION FOR EXTENSION OF TIME
IN WHICH TO RESPOND TO PLAINTIFF’S MOTION FOR ATTORNEYS FEES
Pursuant to Local Rule 7(b), the Defendant, US Investigations Services, Inc.
("USIS"), by and through its attorneys, McCarter & English, respectfully request that this Court
grant it an additional fourteen (14) days to respond to Plaintiffs Motion for Attorneys Fees. In
support of this motion, the undersigned counsel for Defendant represents as follows:
l. Defendant respectfully requests an extension of time of fourteen (14) days
to respond to Plaintiffs Motion for Attorneys Fees. If the Court grants this motion, Defendant’s
response will be due on or before August 6, 2004.
2. The parties have reached a tentative settlement agreement that will resolve
Plaintiff s Motion for Attomeys Fees without the need for Defendant to file a response.
However, the parties are still in the process of negotiating and finalizing the settlement
documents. The additional time is necessary so that the parties can finalize these settlement
documents. In addition, Attomey Mark Carey, counsel for Plaintiff, was on vacation during the

Case 3:03-cv-00623-CFD Document 35 Filed 07/23/2004 Page 2 of 3
week of July 12th and unable to review the settlement documents with his client until he returned
on July 19, 2004.
3. This is the fourth extension filed by Defendant for responding to
Plaintiff s Motion for Attomeys Fees.
4. Defendant has contacted Attorney Carey and he has indicated that he does
not object to this motion being granted.
THE DEFENDANT,
US INVESTIGATIONS SERVICES, INC.,
BY MCCARTER & ENGLISH
ITS ATTORNEYS
By {chef Hauer
Richard Voigt (CT 05320)
Robert J. Gallo (CT 19982)
CityP1ace I — 185 Asylum Street
Hartford, Connecticut 06103
(860) 275-6700
[email protected]
[email protected]
-2- y

Case 3:03-cv-00623-CFD Document 35 Filed 07/23/2004 Page 3 of 3
CERTIFICATE OF SERVICE
This is to certify that a copy of the foregoing Defendant's Fourth Motion for
Extension of Time in Which to Respond to Plaintiff s Motion for Attorneys Fees has been
mailed, postage prepaid, this §j_°`day of July, 2004 to:
Mark P. Carey, Esq.
1 Carey & Associates, P.C.
7l Old Post Road, Suite One
Southport, CT 06490
Robert J. Gallo
mnrroizo; 618667.01
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