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


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Case 3:03-cv-00986-JCH Document 56 Filed 08/20/2004 Page 1 of 3
UNITED STATES DISTRICT COURT
DISTRICT OF CONNECTICUT Q
SUSAN E. WOOD, CIVIL ACTION NO.
3:03-CV-986 (ICH)
Plaintiff,
v.
SEMPRA ENERGY TRADING CORPORATION,
r August 19, 2004 r
Defendant.
DEFENDANT’S AMENDED MOTION FOR PERMISSION TO EXCEED THE TEN-PAGE
’ LIMIT WITH RESPECT TO DEFENDANT’S REPLY MEMORANDUM OF LAW IN
FURTHER SUPPORT OF ITS MOTION FOR PARTIAL SUMMARY JUDGMENT
Defendant, Sempra Energy Trading Corp. ("Sempra"), respectfully moves the Court for
permission to exceed the ten-page limit contained in D. Conn. L. Civ. R. 7(d) with respect to Sempra’s
reply memorandum of law in further support of its motion for partial summary judgment, filed on August
6, 2004. Sempra’s reply memorandum is twenty-seven pages in length, exclusive of its one sentence, gg
forma conclusion.
Sempra submits that an extension of the page limit is appropriate here, given that the
Complaint tiled in this matter contains fourteen separate counts, and Sempra is moving for summary
judgment on all but one of those counts. Further, Plaintiffs opposition brief is 36 pages long and is A
’ comprised of numerous, detaile_d arguments and allegations that Sempra must address in order to clarify
the record. Accordingly, although Sempra is mindful ofthe requirement in D. Conn. L. Civ. R. 7(d) that
its reply brief must be "strictly confined to a discussion of the matters raised in [Plaintiff’ s Opposition],"
and has made every reasonable effort to be as efficient as possible with their allotted pages, it respectfully
· submits that an adequate reply cannot be accomplished within the Court’s standard page limit.
ORAL ARGUMENT NOT REQUESTED
TESTIMONY NOT REQUIRED

‘ Case 3:03-cv-00986-JCH Document 56 Filed 08/20/2004 Page 2 of 3
Therefore, Sempra respectfully requests that the Court grant the instant motion permitting
it to exceed Local Rule 7(d)’s ten-page limit with respect to its reply brief on summary judgment. P
Dated: Stamford, Connecticut
August 19, 2004 `
Respectfully Submitted,
BY: QIIA) . pg
Mary C. Dollarhide (ct1225l)
1 ( Peter M. Schultz (ctl9425) V
Paul, Hastings, Janofsky & Walker LLP
. 1055 Washington Boulevard
Stamford, CT 06901-2217
· Telephone: (203) 961-7400
Fax: (203) 359-3031
Counsel for Defendant
-2-

` Case 3:03-cv-00986-JCH Document 56 Filed 08/20/2004 Page 3 of 3
CERTIFICATE OF SERVICE
This is to certify that Va true and correct copy of the foregoing Defendant’s Amended
Request to Exceed Page Limit was served on the following counsel of record via U.S. Mail on this 19th
day of August 2004: .
Brendan J. O’Rourke A
O’Rourke & Associates, LLC
27 Pine Street V
New Canaan, CT 06840
Peter M. Schultz
STM /280582.}
-3- ·