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

Case 3:03-cv-00987-CFD

Document 17

Filed 05/13/2004

Page 1 of 2

UNITED STATES DISTRICT COURT DISTRICT OF CONNECTICUT JOSEPH INTURRI, ET AL. Plaintiffs vs. : CIVIL ACTION NO. 3:03CV987 (CFD)

:

CITY OF HARTFORD, CONNECTICUT; and BRUCE P. MARQUIS, Defendants :

MAY 13, 2004

MOTION FOR EXTENSION OF TIME The plaintiffs, JOSEPH INTURRI, ET AL., pursuant to Local Rule 7(b), hereby request an extension of time, up to and including May 21, 2004, within which to file dispositive motions. In support of this motion, the plaintiffs represent as follows: The parties were previously granted until May 14, 2004 to complete discovery and file dispositive motions. In order to present this case for resolution in the most expeditious manner, the parties intend to file cross-motions for summary judgment based upon a joint stipulation of facts. The parties have commenced preparation of their dispositive motions, but have not yet completed work thereon. The additional time is needed to finalize the stipulation of facts and/or exhibits and to complete the parties' respective memoranda. The undersigned telephoned defendants' counsel in order to ascertain her position in connection with this motion. Defendants' counsel has indicated that she does not object to the granting of this extension and that the defendants join in this request. This is the plaintiffs' first request to extend the time for filing dispositive motions. WHEREFORE, plaintiffs move for an extension up to and including June 18, 2004 for

Case 3:03-cv-00987-CFD

Document 17

Filed 05/13/2004

Page 2 of 2

filing dispositive motions. PLAINTIFFS

BY Jon L. Schoenhorn Their Attorney 97 Oak Street Hartford, CT 06103 Federal Bar No. ct.00119 Telephone (860) 278-3500 Facsimile (860) 278-6393

CERTIFICATION This is to certify that a copy of the foregoing was mailed, postage prepaid, this 13th day of May 2004 to: Helen Apostolidis Assistant Corporation Counsel 550 Main Street Hartford, CT 06103

Jon L. Schoenhorn