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

Case 3:03-cv-00948-JCH

Document 22

Filed 03/29/2005

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UNITED STATES DISTRICT COURT DISTRICT OF CONNECTICUT ANTHONY BONTATIBUS, v. DUNCAN AYR, ET AL. : : : : : 3:03cv00948 (JCH) MARCH 28, 2005

PLAINTIFF'S MOTION FOR PERMISSION TO FILE BRIEF OUT OF TIME

The plaintiff requests permission to file this brief out of time. In support hereof, he represents as follows: 1. The plaintiff's memorandum in opposition to the defendants' motion for summary judgment was due on March 1, 2005, and that deadline had previously been extended upon request of the plaintiff. 2. Plaintiff's counsel was involved in a complex trial requiring extensive preparation on short notice for the latter part of February and early March, resulting in his inability to keep up with briefing schedules in several cases, including the instant case. 3. I have requested that my adversary consent to this motion, and he reports that he takes no position. 4. 5. The defendants are not prejudiced should the Court grant this request. The plaintiff desires that these issues be decided on the merits.

Case 3:03-cv-00948-JCH

Document 22

Filed 03/29/2005

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THE PLAINTIFF By__________________________ NORMAN A. PATTIS 649 Amity Road Bethany, CT 06524 203.393.3017 203.393.9745 ct 13120

CERTIFICATION The foregoing was mailed this 28th day of March 2005 to James Tallberg, Updike, Kelly & Spellacy, One State Street, P.O. Box 231277, Hartford, CT 06123.

__________________________ NORMAN A. PATTIS