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

Case 3:03-cv-00623-CFD Document 33 Filed 07/09/2004 Page 1 of 3
UNITED STATES DISTRICT COURT
DISTRICT OF CONNECTICUT
KAREN HARTER, )
Plaintifi g CIVIL ACTION NO.
) 3:03CV623 (CFD)
v. )
)
US INVESTIGATIONS SERVICES, INC., )
Defendant. i July 9, 2004
DEFENDANT'S THIRD 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 Plaintiff’ s 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 tor Attorneys Fees. lfthe Court grants this motion, Defendant’s
response will be due on or before July 23, 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 additional time is necessary so that the parties can draft and finalize settlement
documents. In addition, Attorney Mark Carey, counsel for Plaintiff will be on vacation during
the week of July 12th and unable to review the settlement documents until he returns on July 19,
2004.

Case 3:03-cv-00623-CFD Document 33 Filed 07/09/2004 Page 2 of 3
3. This is the third extension iiled by Defendant for responding to Plaintiff s
Motion for Attorneys Fees.
4. Defendant has contacted Attomey Carey and he has indicated that he does
not obj ect to this motion being granted.
THE DEF ENDAN T,
US INVESTIGATIONS SERVICES, INC.,
BY MCCARTER & ENGLISH
ITS ATTORNEYS

Richard Voigt (CT 05320)
Robert J. Gallo (CT 19982)
CityPlace I- 185 Asylum Street
Hartford, Cormecticut 06103
(860) 275-6700
[email protected]
[email protected]
l -2-
l

Case 3:03-cv-00623-CFD Document 33 Filed 07/09/2004 Page 3 of 3
CERTIFICATE OF SERVICE
This is to certify that a copy of the foregoing Defendants Second Motion for
Extension of Time in Which to Respond to Plaintiffs Motion for Attorneys Fees has been
i mailed, postage prepaid, this gif; day of July, 2004 to:
Mark P. Carey, Esq.
Carey & Associates, P.C.
71 Old Post Road, Suite One
Southport, CT 06490
l
Robert J. Gallo
HARTFORD: 618667.01
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