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

Case 3:03-cv-00987-CFD

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Filed 03/30/2004

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UNITED STATES DISTRICT COURT DISTRICT OF CONNECTICUT ________________________________ JOSEPH INTURRI, ET AL : CIVIL ACTION NO. Plaintiffs : 3:03 CV 987 (CRD) v. : : CITY OF HARTFORD, ET AL : MARCH 30, 2004 Defendants : _________________________________: MOTION FOR EXTENSION OF TIME The defendants, CITY OF HARTFORD and BRUCE P. MARQUIS, pursuant to Local Rule 7(b), hereby request an extension of time, up to and including May 14, 2004, within which to file dispositive motions. In support of this motion, the defendants represent as follows: The parties were previously granted until March 3, 2004 to complete discovery and until March 31, 2004 to 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

Case 3:03-cv-00987-CFD

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finalize the stipulation of facts and/or exhibits and to complete the parties' respective memoranda. The undersigned telephoned plaintiffs' counsel in order to ascertain his position in connection with this motion. Plaintiffs' counsel has indicated that he does not object to the granting of this extension and that the plaintiffs join in this request. This is the defendants' first request to extend the time for filing dispositive motions. WHEREFORE, defendants move for an extension up to and including May 14, 2004 for filing dispositive motions. DEFENDANTS BY_____________________________ Helen Apostolidis Assistant Corporation Counsel Their Attorney 550 Main Street Hartford, CT 06103 Federal Bar No. Ct 05534 Telephone (860) 543-8575 Facsimile (860) 722-8114

CERTIFICATION

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Case 3:03-cv-00987-CFD

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This is to certify that a copy of the foregoing was mailed, postage prepaid, this 30th day of March 2004 to: Jon L. Schoenhorn, Esq. 97 Oak Street Hartford, CT 06106 ____________________________ Helen Apostolidis

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