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

€ _ _ _ Case 3:03-cv—OO9?5WIG Document 33 Filed O1/O€§OO4 Page 1 of 4 [
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. UNITED STATES DISTRICT COURT , _ .
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’ SAMMIE GOSS CASE NO. 03-CV—935 (WIG)
i PLAINTIFF
VS.
FAIRFIELD HOUSING AUTHORITY, ET
AL.
DEFENDANTS I
JANUARY 8, 2004 .
MOTION FOR ENLARGEMENT OF TIME
The defendants, Fairfield Housing Authority, Charles Feld, Marilyn McNee, and David
Belcher ("Defendants"), hereby move for an enlargement of time in which to file an answer and
affirmative defenses and/or otherwise respond to the Complaint filed by the pm se plaintiff,
Sammie Goss ("P1aintiff"). In support of this motion the Defendants represent the following:
1. The Plaintiff] who is proceeding in forma pauperis, attempted service by mail
pursuant to Fed. R. Civ. P. 4, with a request for waiver of service dated July 9, 2003. These
Defendants waived service within the time set forth in the request for waiver. The undersigned
counsel appeared by notice dated August 27, 2003, which was filed in Court on August 28,
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[ 2003. The handwritten complaint as it now stands was drafted and filed by the pro se Plaintiff,
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l however, and is not easily amenable to response or motion.
2. The case has been referred to Judge Garfinkel for all purposes.
3. At a status conference before Judge Gartlnkel on November 3, 2003, the Plaintiff
represented that she had spoken to attorney Edwin Farrow, who would be entering an
appearance after his admission to practice before the United States District Court for the District `
of Connecticut. i
4. The case has since been set down for a Scheduling Conference in the Judge’s l
Courtroom on January 20, 2004.
5. The undersigned spoke to Attorney Farrow by telephone on January 5, 2004, and I
Attorney Farrow stated that his application for admission to the District Court was granted and I
that he would be reviewing the Complaint and tiling an appearance forthwith. J
6. Given that Attorney Farrow has not been able to discuss the Complaint in depth
with counsel, the Defendants request an enlargement of time to enable them to confer with
Plaintiff s counsel upon his appearance, and to discuss the Complaint and matters of scheduling
accordingly. l
7. Pursuant to Loc. R. Civ. P. 7(b), the undersigned counsel states that he discussed
the need for this enlargement of time in light of Attorney Farrow’s imminent appearance, and
that Attorney Farrow consented to this Motion. In addition, the undersigned on this date also
telephoned Assistant U.S. Attorney Douglas Morabito, who represents the United States l
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. Case 3:O3—cv—OO93€-\>5V|G Document 33 Filed O1/O8i2004 Page 3 of 4
Department of Housing and Urban Development ("HUD"), and who stated that he has no I
objection. The undersigned also telephoned the pro se Plaintiff to inform her of the filing of this ,
Motion, and left a voice mail message. As of the filing of this Motion, the undersigned is aware
of no objection.
8. Pursuant to Loc. R. Civ. P. 7(b), the undersigned states that this is the I
Defendants’ fifth motion for enlargement of time to file an answer and affirmative defenses or i
otherwise respond to the Plaintiff s complaint.
WHEREFORE, the Defendants request that this Motion be granted and that the time to
file an answer and defenses and/or otherwise respond to the complaint be extended 20 days from
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the date of this motion, or until January 28, 2004.
THE DEFENDANTS
FAIRFIELD HOUSING AUTHORITY, CHARLES
FELD, MARILYN MCNEE, AND DAVID
BELCHER ~’
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Brr Q? .. ..
thew M /rnan (ct 08966)
Pullman & Comley, LLC
850 Main Street, P.O. Box 7006 i
Bridgeport, CT 06601-7006
(203) 330-2000
Facsimile (203) 576-8888
Their Attorneys I
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‘ . ‘ • Case 3:03-cv—OO96555W|G Document 33 Filed O1/063004 Page 4 of 4 [
CERTIFICATION
Pursuant to Fed. R. Civ. P. Rule 5 (b), I hereby certify that a copy of the above was
mailed on January 8, 2004 to all counsel and pro se parties of record.
For the plaintiff SAMMIE GOSS:
Sammie Goss, Pro Se
10 Ridgeley Avenue
Fairfield, CT 06825 ,
Douglas P. Morabito, Esq.
U.S. Attorney’s Office
157 Church Street, 23rd Floor k
New Haven, CT 06510 l
Edwin Farrow, Esq.
211 State Street
Bridgeport, Connecticut l
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Matth w M. Hausman (ct80966)
Br-[mss?10.5/Mxi-1/soszazvi
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