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


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Case 3:03-cv-00986-JCH Document 54 Filed 08/06/2004 Page 1 of 3
UNITED STATES DISTRICT COURT
DISTRICT OF CONNECTICUT
SUSAN E. WOOD, CIVH. ACTION NO.
3:03-CV-986 (J CH)
Plaintiff,
V. .
SEMPRA ENERGY TRADING CORPORATION, .
August 6, 2004
Defendant.
DEFENDANT’S MOTION FOR PERMISSION TO EXCEED THE 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 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, submitted herewith.
Sempra submits that an extension of the page limit is appropriate here, given that the
' _ Complaint filed in this matter contains fourteen separate counts, and Sempra is moving for summary
judgment on all but one of those counts. Further, Plaintiff` s opposition brief is 36 pages long and is ‘
· comprised of numerous, detailed arguments and allegations that Sempra must address in order to clarify —
the record. Accordingly, although Sempra is mindful of the 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 [Plainti-ff'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.
· _ 2 i V
. - Therefore, Sempra respectfully requests that the Court grant the instant motion permitting
it to exceed Local Rule 7(d)’s page limit and file the attached reply brief.
ORAL ARGUIVIENT NOT REQUESTED
TESTIMONY NOT REQUIRED

‘ Case 3:03-cv-00986-JCH Document 54 Filed 08/06/2004 Page 2 of 3
Dated: Stamford, Connecticut
August 6, 2004 3
’ Respectfully Submitted,
0 Byr CX ‘
_ Mary C. Dollarhi e (ctl2251)
0 Peter M. Schultz (ct19425)
Paul, Hastings, J anofsky & Walker LLP
1055 Washington Boulevard
Stamford, CT 06901-2217
Telephone: (203) 961-7400
- Fax: (203) 359-3031
Counsel for Defendant _
-2- (

" ‘ N Case 3:03-cv-00986-JCH Document 54 Filed 08/06/2004 Page 3 of 3
S CERTIFICATE OF SERVICE U
This is to certify that a true and correct copy of the foregoing Defendant’s Request to
Exceed Page Limit was served on the following counsel of record via UPS (next business day delivery) I
on this 6th day of August 2004:
- Brendan J. O’Rourke
O’Rourke & Associates, LLC
27 Pine Street
W New Canaan, CT 06840
y Peter M. Schultz
sm/:19794.1 I _
-3-