Free Motion for Extension of Time to File Response/Reply to Motion - District Court of Connecticut - Connecticut

Case 3:03-cv-00948-JCH

Document 20

Filed 01/04/2005

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UNITED STATES DISTRICT COURT DISTRICT OF CONNECTICUT ANTHONY BONTATIBUS, Plaintiff VS. DUNCAN AYR and TOWN OF BRANFORD, Defendant : : 3:03CV00948(JCH) : : : : : JANUARY 3, 2005

PLAINTIFF'S NUNC PRO TUNC REQUEST FOR A SECOND EXTENSION OF TIME WITHIN WHICH TO RESPOND TO SUMMARY JUDGMENT MOTION

The plaintiff, through counsel, respectfully requests that this court grant a second extension of time to respond to the defendants' motion for summary judgment. In support hereof, the undersigned represents as follows: 1. 2. I represent the plaintiff in this action. The defendants have filed a motion for summary judgment and the response to that motion is due on November 22, 2004. The plaintiff obtained an extension of time to respond to that brief. 3. The underlying dispute was the subject of three felony-murder trials and one civil trial. All trials resulted in mistrials. 4. I have been unable to respond to the defendants' motion within the 1

Case 3:03-cv-00948-JCH

Document 20

Filed 01/04/2005

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period required by law due to my decision to leave the firm Williams and Pattis, LLC, and form a firm of my own. Planning and executing the move, together with the time involved starting a new office has proven more time-consuming than I had expected it to be. 5. 6. This is the second such request. I have conferred with my adversary in this action, Attorney James Tallberg, and he consents to my request for an extension of time. 7. I am requesting until March 1, 2005 to complete the brief.

THE PLAINTIFF ANTHONY BONTATIBUS

BY__________________________________ NORMAN A. PATTIS Williams and Pattis, LLC 51 Elm Street, Suite 409 New Haven, CT 06510 Telephone: (203) 562-9931 Fed Bar No. ct13120 His Attorney

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Case 3:03-cv-00948-JCH

Document 20

Filed 01/04/2005

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CERTIFICATION This is to certify that a copy of the foregoing was sent via first class mail, postage prepaid, on January 3, 2005 to the following parties and counsel of record:

James N. Tallberg, Esq. Updike, Kelly & Spellacy, PC One State St., P.O. Box 231277 Hartford, CT 06123-1277

NORMAN A. PATTIS

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