Free Motion for Extension of Time to File Response/Reply to Motion - District Court of Connecticut - Connecticut

ase 3:03-cv-01009-SRU Document 68 Filed 12/22/2004 Page 1 of 3
. ‘ I
I Fire I
I Q I
I NUI UH, 22 I
I UNITED STATES DISTRICT; T I I
I QI@ICT OF CONNECIQIT ' I I
` `
I JOSEPH ATTIAS & HAIM ATTIAS : CIVIL NO. 3:03 CV 01009 (SRU)
I Piamurrs ; - ·
l PATRONS MUTUAL INSURANCE ; I
I COMPANY OF CONNECTICUT :
Defendant : DECEMBER 2, 2004
I I
PLAINTIFIQE/IOTION FOR ENLARGEMENT I
I OF TIME TOP RESPOND TO DEFENDANT’S MOTION FOR SUMMARY
I JUDGMIIQNQ DATED DECEMBER 14, 2004 I
» I
I
The Plaintiffs Joseph & Haim Attias, hereby request through their counsel for an i
I enlargement of time until February I5, 2005 to respond to the defendant’s motion for
I summary judgment dated December I4, 2004 for the following reasons:
I 1. The plaintiff has filed a Enlargement of Time ofthe scheduling orders
I contemporaneous with the filing of this motion seeking enlargement of time to file
I resolve outstanding discovery disputes, file dispositive motions and file the Joint Trial
I Brief until February 15, 2005.
I 2. The parties have several unresolved motions with respect to various
I discovery issues not yet addressed by the court
I
I
. I
I I
,.... __ H __ M __ M H V H M H M H rm-nr""JT"`-"7"‘-"—···—~»----~7...;
g___;t; __--g -- as -- as .. A .. as __ I __ I J iill

`
Case 3:03-cv-01009-SRU Document 68 Filed 12/22/2004 Page 2 of 3 1 i
I
· I
a l
3. A telephone conference was conducted with the on October 4, 2007 to tl E
address these issues, however the Court was not able at that time to address all pending
· !
motions. l
4. The parties agreed to schedule another telephonic conference at a later R
time to address the remaining outstanding issues. The conference still needs to be p i I
scheduled, however undersigned counsel has contacted the Couit for available dates in l
January. R
5. The plaintiffs need to have the outstanding discovery issues resolved .
prior to being able to prepare and file dispositive motions and properly respond to the i
l
defendant’s motion. !
Accordingly, the plaintiffs are seeking an enlargement of time to respond to the
defendant’s motion for summary judgment until February 15, 2005.
The defendant though Attorney Heather Adams-Beman agrees to this request.
;$ l
l
t ; 1
I l
1
l i
Ԥ
l
l
2 = i
l

‘ " ‘|
- a
Case 3:03-cv-01009-SRU Document 68 Filed 12/22/2004 Page 3 of3 II l
» , _ Q
l
THE 1>LA1NrrrF, j
·/‘’' { ././/— —-#37
BY ,--·`:it-Yi ` `'· 3./~ ··‘/ ` ''0 _ l
Chegyll . `effeman 2
Faver die; Heffernan ·
2842 C·ld Dixwell Avenue
Hamden, Connecticut 0651 8
Telephone: 203-288-8266 p -! {
Facsimile: 203-288-4702 ` Q l
Fed BarNo.:CT 06473 ` 5
CERTIFICATION
5 I
ia t
I hereby certify that a copy of the foregoing was sent by first class mail, postage prepaid
this 21S' day of December 2005,to:
Joel J. Rottner, Esq.
Heather Adams-Beman, Esq.
Skelley Rottner P.C.
PO Box 340890 Q1
Hartford, CT 06l34—0890 ..-- · -··---
llll wr/_,,.~»#‘“" I _
CI`'
Cheryl . C C an l
l
I
l I
l
l
t I

l
gh l
li /
3
l
il
. I