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

Case 3:03-cv-00943-AWT

Document 219

Filed 09/08/2008

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UNITED STATES DISTRICT COURT DISTRICT OF CONNECTICUT

GARY SESSION

VS.

EDWIN RODRIGUEZ, ET AL.

: : : : : : :

CIV NO.

3:03CV00943 (AWT)

SEPTEMBER 8, 2008

DEFENDANT CITY OF NEW HAVEN'S MOTION FOR EXTENSION OF TIME WITHIN WHICH TO FILE RESPONSE TO PLAINTIFF'S RULE 60(b) MOTION FOR RELIEF Defendant City of New Haven, pursuant to Fed. R. Civ. P. 7(b) and D. Conn. L. Civ. R. 7(b), hereby moves the Court to extend the time for filing a response to plaintiff's Motion for Relief for an additional thirty (30) days, up to and including October 10, 2008, on the grounds that undersigned counsel's only prior involvement in this file was to represent non-party personnel from the New Haven Department of Police Service at their depositions that took place subsequent to the defendant City of New Haven being terminated as a party from this case as a result of summary judgment being granted, that the

undersigned was not involved in the representation of the City of New Haven while it was still an active party to this case, nor was he involved in the preparation the summary motion and supporting documents filed on behalf of this defendant, and that the attorneys from the Office of the Corporation

ORAL ARGUMENT NOT REQUESTED

Case 3:03-cv-00943-AWT

Document 219

Filed 09/08/2008

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Counsel of the City of New Haven who were so involved, are no longer employed by the Office of Corporation Counsel. Undersigned counsel, who has only been recently delegated responsibility for this aspect of this case, and will need to review a rather voluminous file in order to adequately respond to this motion. .

In accordance with D. Conn. L. Civ. R. 7(b) the undersigned represents that telephonic contact was made with plaintiff's counsel, Attorney John A. Pinheiro, and that Attorney Pinheiro informed the undersigned that he has no objection to this extension of time being granted. This is defendant City of New Haven's first request for an extension of time to file a response to plaintiff's Rule 60(b) Motion for Relief.

THE DEFENDANT, CITY OF NEW HAVEN

BY:

__________/s/____________ Michael A. Wolak, III Assistant Corporation Counsel City of New Haven Office of Corporation Counsel 165 Church Street New Haven, CT 06510 Tel. #: (203)946-7970 Fax #: (203) 946-7942 E-mail: [email protected] Fed. Bar #ct12681 Its Attorney

Case 3:03-cv-00943-AWT

Document 219

Filed 09/08/2008

Page 3 of 3

CERTIFICATION I hereby certify that on September 8, 2008, a copy of the foregoing was filed electronically and served by mail on anyone unable to accept electronic filing. Notice of this filing will be sent by e-mail to all parties by operation of the Court's electronic filing system or by mail to anyone unable to accept electronic filing as indicated on the Notice of Electronic Filing. Parties may access this filing through the Court's CM/ECF System.

_____________/s/_____________ Michael A. Wolak, III