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

Case 3:03-cv-00986-JCH Document 52 Filed 07/27/2004 Page 1 of 3
UNITED STATES DISTRICT COURT
DISTRICT OF CONNECTICUT
SUSAN E. WOOD, CIVIL ACTION NO.
3 :03-CV-986 (J CH)
Plaintiff
v.
SEMPRA ENERGY TRADING
. CORPORATION, July 26, 2004
Defendant. ·
DEFENDANT’S MOTION FOR EXTENSION OF TIME TO FILE REPLY BRIEF IN
FURTHER SUPPORT OF ITS MOTION FOR SUMMARY JUDGMENT
Pursuant to Rule 7(b) ofthe Local Rules of Civil Procedure, Defendant respectfully
moves the Court for a ten (10) day extension of time within which to file a reply brief in further
support of its motion for summary judgment.
There is good cause to grant Defendant’s motion. Plaintiff has submitted voluminous
papers in opposition to Defendant’s summary judgment motion after seeking two extensions of
time totaling more than thirty-five (35) days. Defendant requires a brief extension of time in
order to thoroughly respond to Plaintiffs numerous arguments.
On the afternoon of July 23, 2004, Defendant’s counsel sent an e-mail message to
Plaintiffs attorney, Brendan O’Rourke, explaining the nature of the instant motion and seeking
his consent to same. Attorney O’Rourke has not yet advised as to whether Plaintiff consents to
this motion. Defendant has therefore been unable to ascertain Plaintiff s position with respect to
the requested ten-day extension, despite diligent effort.
ORAL ARGUMENT NOT REQUESTED
TESTIMONY NOT REQUIRED

· Case 3:03-cv-00986-JCH Document 52 Filed 07/27/2004 Page 2 of 3
The current deadline for filing a reply brief is July 27, 2004. Should the Court grant this
request, the new filing deadline will be August 6, 2004. Defendant does not intend to seek any
J further extensions of time with respect to this deadline. This is Defendant’s first such request
with respect to this deadline.
Dated: Stamford, Connecticut
July 26, 2004 _
Respectfully Submitted,
By: g,-2
Mary C. Dollarhide (ct1225 1) .
Peter M. Schultz (ctl9425)
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- ,

c I Case 3:03-cv-00986-JCH Document 52 Filed 07727/2004 I Page
CERTIFICATE OF SERVICE y
4 This is to certify that a true and correct copy of the foregoing Defendant’s Motion
for Extension of Time was served on the following counsel of record via U.S. Mail on this 26th
day of July 2004:
Brendan J. O’Rourke 4
O’Rourke & Associates, LLC
27 Pine Street
New Canaan, CT 06840
Peter M. Schultz
STM /279049.1 I
-3-