Free Motion for Leave to File - District Court of Connecticut - Connecticut


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Pages: 2
Date: May 6, 2005
File Format: PDF
State: Connecticut
Category: District Court of Connecticut
Author: unknown
Word Count: 414 Words, 2,417 Characters
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https://www.findforms.com/pdf_files/ctd/22939/86.pdf

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{ i I ase 3:03-cv-01009-6IiU Document 86 Filed 05/05/2(§l5 Page 1 of 2
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{ UNITED STATES DISTRICT COURT;}
DISTRICT OF CONNECTICUT an H l .
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' JOSEPH ATTIAS & HAIM ATTIAS : CIVIL NO. 3:03 CV 01009 (SRU)
Plaintiffs : {
j PATRONS MUTUAL INSURANCE 1 N
l COMPANY OF CONNECTICUT :
j Defendant : APRIL 28, 2005
PLAIN'I`IFFS’ REQUEST FOR LEAVE TO FILE REPLY BRIEF TO
DEFENDANT’S OBJECTION TO MOTION FOR SUMMARY JUDGMENT

Pursuant to Local Rule 9 (b) and (c) the Plaintiffs Joseph & Haim Attias, hereby
request through their counsel for permission to tile a reply brief to the defendanfs
Objection to Plaintiff Motion for Summary and to be permitted to file said brief on or j
before May 10, 2005 for the following reasons:
l
l. The Plai11tiffs’ motion for Summary Judgment was filed on or about i
February 14, 2005; \
2. The Defendant filed its objection to said motion on or about April 21,
2005
3. Undersigned Counsel for the Plaintiffs was away on a family vacation
until April 25, 2005;
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I ase 3:03-cv-O1009@U Document 86 Filed 05/0560535 Page 2 0f 2
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4. In the Objection to the Summery Judgment Motion, the Defendant I
I appears to be arguing on cause of action not plead in its counterclaim.
5. Therefore a reply brief is appropriate to address these unpled claims of
the defendant and the additional time to file such is also required to
I properly and fully reply to the Defendant’s objection to the pIaintiffs’
I motion.
I 6. Attorney Heather Adams—Beman has no objection to the granting of this
- request.
WHEREFORE, the plaintiffs’ request permission to file a reply brief to the
defendant’s Objection to the Plaintiffs’ Motion for Summary Judgment by May 10, 2005.
THE PLAINTIFF, _
_
,7 Cheryl yi · n I
Fav · ernan
28 : • Dixwell Avenue
Hamden, Connecticut 0651 8
Telephone: 203-288—8266
Facsimile: 203—288—4702
Fed Bar No.:CT 06473 I
CERTIFICATION
I hereby certify that a copy ofthe foregoing was sent by first class mail, postage prepaid
this 28"' day of April 2004, to:
Joel J . Rottner, Esq.
Heather Adams-Beman, Esq.
Skelley Rottner P.C.
PO Box 340890
Hartford, CT 06134-0890
Cheryl . Heffernan I
2 I