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

Case 3:03-cv-00623-CFD Document 31 Filed 06/24/2004 Page 1 of 3
_ UNITED STATES DISTRICT COURT
DISTRICT OF CONNECTICUT
KAREN HARTER, )
Plaintiff CIVIL ACTION NO.
) 3:03CV623 (CFD)
V- )
)
US INVESTIGATIONS SERVICES, INC., )
Defendant. 3 June 24, 2004
DEFENDANT'S SECOND 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, respectihlly request that this Court
grant it an additional fourteen (14) days to respond to Plaintiffs Motion for Attomeys 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, Det`endant’s
response will be due on or before July 9, 2004.
2. The parties are engaged in settlement discussions that may resolve
Plaintiffs Motion for Attomeys Fees without the need for Defendant to file a response. The
additional time is necessary so that the parties can devote all of their time and efforts to
settlement negotiations.
3. This is the second extension filed by Defendant for responding to
Plaintiffs Motion for Attomeys Fees.
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Case 3:03-cv-00623-CFD Document 31 Filed 06/24/2004 Page 2 of 3
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4. Defendant has contacted Attomey Mark P. Carey, counsel for the Plaintiff
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

Richard Voigt (CT 05320)
- Robert J. Gallo (CT 19982)
CityPlace I- 185 Asylum Street
Hartford, Comiecticut 06103
(860) 275-6700
[email protected]
[email protected]
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Case 3:03-cv-00623-CFD Document 31 Filed 06/24/2004 Page 3 of 3
CERTIFICATE OF SERVICE
This is to certify that a copy of the foregoing Defendant‘s Second Motion for
Extension of Time in Which to Respond to Plaintiff s Motion for Attorneys Fees has been
mailed, postage prepaid, this gh day of June, 2004 to:
Mark P. Carey, Esq.
Carey & Associates, P.C.
71 Old Post Road, Suite One
Southport, CT 06490
Robert J. Gallo
11ARrro1z¤; 617661.01
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