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

Case 3:03-cv-00623-CFD Document 29 Filed 06/10/2004 Page 1 of 3
UNITED STATES DISTRICT COURT
DISTRICT OF CONNECTICUT
KAREN HARTER, )
Plaintiff] l CIVII. ACTION NO.
) 3:O3CV623 (CFD)
v. )
)
US INVESTIGATIONS SERVICES, INC., )
Defendant. 3 June 10, 2004
DEFENDANT'S 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
i support of this motion, the undersigned counsel for Defendant represents as follows:
1. 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, l)etendant’s
response will be due on or before June 25, 2004.
2. Defendant is in the process of preparing a response to Plaintiffs Motion
for Attorneys Fees, but will be unable to complete its response before June 25, 2004. Additional
time is necessary due to pressing litigation demands on Defendant’s counsel, including a
mediation and a settlement conference out of state.
3. This is the first extension filed by Defendant for responding to Plaintiff s
Motion for Attomeys Fees.

Case 3:03-cv-00623-CFD Document 29 Filed 06/10/2004 Page 2 of 3
4. Defendant attempted to contact Attomey Mark P. Carey, counsel for the
Plaintiff, to determine whether he consents or objects to this motion being granted, but Attorney
Carey was unavailable.
THE DEFENDANT,
US INVESTIGATIONS SERVICES, INC.,
BY MCCARTER & ENGLISH
ITS ATTORNEYS
BY
Richard Voigt (CT 05320)
Robert J. Gallo (CT 19982)
CityPlace I- 185 Asylum Street
Hartford, Connecticut 06103
(860) 275-6700
[email protected]
[email protected]
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Case 3:03-cv-00623-CFD Document 29 Filed 06/10/2004 Page 3 of 3
CERTIFICATE OF SERVICE
This is to certify that a copy of the foregoing Defendants Motion for Extension of
Time in Which to Respond to Plaintiff s Motion for Attorneys Fees has been mailed, postage
prepaid, this @ 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
I
HARTFORD; 616856.01
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