Free Docket Annotation - District Court of Connecticut - Connecticut

· Case 3:03-cv-01009-SRU Document 93 Filed 05/11/2005 Paget of 3 <
FILED P
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DISTRICT OF CONNECTICUT {
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- JOSEPH ATTIAS & HAIM ATTIAS 2 CIVIL NO. 3:03 CV 01009 (SRU)
Plaintiffs ; l
PATRONS MUTUAL INSURANCE :
COMPANY OF CONNECTICUT :
Defendant 2 APRIL 28, 2005 l
PLAINTIFFS’ REQUEST FOR LEAVE TO FILE RESPONSE BRIEF TQ l
DEFENDANT’S REPLY BRIEF TO PLAINTIFFS’ OBJECTION DEFENDAINE
TO MOTION FOR SUMMARY JUDGMENT
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Pursuant to Local Rule 9 (b) and (c) the Plaintiffs Joseph & Haim Attias, hereby l
request through their counsel for permission to file a response brief to the defendant’s
reply to the plaintiffs’ Objection to Defendant’s Motion for Summary and to be permitted l
to file said brief on or before May l0, 2005 for the following reasons:
1. The Defendant’s motion for Summary Judgment was filed on or about
December 14, 2004;
2. The Plaintiffs filed their objection to said motion on or about February

14, 2005; Q
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Case 3:03-cv-01009-SRU Document 93 Filed 05/11/2005 Page 2 of 3
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3. On or about February 24, 2005, the Defendant sought the Court’s l
permission to conduct additional discovery and file a reply to the
plaintiff` s objection, which was subsequently granted by the Court.
4. The Defendant’s filed that reply on or about April 21, 2005, in which
new areas of law are presented and argued by the defendant in support of
_ its motion for summary judgment and in reply to the Plaintiffs’ objection.
5. Undersigned Counsel for the Plaintiffs was away on a family vacation i
until April 25, 2005; · ·
6. Therefore a response brief is appropriate to address these new legal
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arguments of the defendant and the additional time to file such is also
required to properly and fully respond to the Defendant’s reply brief
7. Attorney Heather Adams-Beman has no objection to the granting of this
request. _ . p
WHEREFORE, the plaintiffs’ request permission to file a response brief to the
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defendant’s Reply to the Plaintiffs’ Objection to the Defendant’s Motion for Summary I
Judgment by May 10, 2005. I
THE PLAINTIFF, T
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BY NI I- l
he . ffernan l
Fav & Heffernan l
2842 Old Dixwell Avenue ,
Hamden, Connecticut 06518 l
Telephone: 203-288-8266
Facsimile: 203-288-4702
Fed Bar No.:CT 06473
2 l

Case 3:03-cv-01009-SRU Document 93 Filed 05/11/2005 Page 3 of 3
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CERTIFICATION I
I hereby certify that a copy ofthe foregoing was sent by first class mail, postage prepaid
this 28m day of April 2004, to:
Joel J. Rotmer, Esq.
Heather Adams-Beman, Esq. _
Skelley Rotmer P.C. ,/Z ' __
PO Box 340890 ‘ h .
Hartford, CT 06134-0890 __ t
Cheryl E. Heffe 1
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