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

UNITED STATES DISTRICT COURT if F5) I
DISTRICT OF CONNECTICUT " ·*
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Plaintiff : CIVIL ACTI I In 5
: 3:03CV00932(?SRU)l U Q ` U _ p g (
v. : ‘l
ATLAS FENCE COMPANY U
D.B.A. ATLAS OUTDOORS : November 26, 2003
Defendant I
PLAINTIFF’S MOTION FOR ENLARGMENT OF TIME TO RESPOND TO
DEFENDANT’S MOTION TO DISMISS, FILED SEPTEMBER 29, 2003 p
Pursuant to Fed. R. Civ. P. 6(b), the Plaintiff, Peter Sym, by and through his l
undersigned attomey, Eugene N. Axelrod of the Employment Law Group, LLC, hereby l
respectfully requests that this Court allow Plaintiff a twenty-one (21) day enlargement of p
time, up to and including December 24, 2003 within which to tile a Memorandum in
Opposition to Defendant’s Motion to Dismiss, tiled September 29, 2003. In support
thereof, Plaintiff represents as follows:
1. Plaintiff commenced this action on May 23, 2003. I
2. Defendant tiled a Motion to Dismiss on September 29, 2003. U
3. Plaintiff is in the final stages of completing his Opposition to the Motion
to Dismiss, and request a brief period of time in which to respond to the
Defendant’s Motion to Dismiss.
4. The attorney assisting in the research and preparation of the Answer to the R
Motion to Dismiss for this case, Melissa Toddy, recently suffered the .
death of her father, resulting in her having to immediately go to
Pennsylvania to be with her family.
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» ‘ Case 3:03-cv-00932-SRU Document 17 Filed 12/O1/2003 Page 2 of 3
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5. Plaintiff does not believe that this request will unduly hinder the
administration of this case. I
6. Pursuant to Rule 9(b)(2) of the Local Rules of Civil Procedure, counsel for
the Plaintiff has inquired of counsel for the Defendant, who has not I
responded as to whether or not he is in agreement to this request.
7. This is the third request for an enlargement of time with respect to this I
matter.
The Plaintiff, I
Peter Sym I
BY I
Eugene N. Axelrod (ct 00309)
The Employment Law Group, LLC
8 Lunar Drive
Woodbridge CT
Tel: (203) 389-6526 ‘
Fax: (203) 3 89-2656 I
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»» —· Case 3:03-cv-OO932—SFiU Document 17 Filed 12/O1/2003 Page 3 of 3

CERTIFICATION
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This mscertify that a copy of the foregoing was mailed iirst class, postage pre- l
paid this; I of November 2003 to:
Michael P. Devlin, Esq.
Thomas A. Carroll, Esq.
Berehem, Moses & Devlin, P.C. {
75 Broad Street
Milford CT 06460 N
Eugene N. Axelrod .
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