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

Case 3:03-cv-00929-AWT

Document 54

Filed 01/24/2005

Page 1 of 3

UNITED STATES DISTRICT COURT DISTRICT OF CONNECTICUT NICHOLAS SICINOLFI, a/k/a NICK SICINOLFI, a/k/a NICHOLAS SARNO, a/k/a NICK SARNO; and THE NICHOLAS-JAMES COMPANY, LLC, Plaintiffs, V. TOWN OF TRUMBULL; MARLIN LIVELY, in his individual capacity only; ANNE MOORE, in her individual capacity only; RICHARD BERNARD, in his individual capacity only; and CHRISTOPHER PAOLETTI, in his individual capacity only. Defendants. : : : : : : : : : : : : : : : : : : : : : : DN. 3:03 CV 929 (AWT)

January 21, 2005

SECOND UNOPPOSED MOTION TO EXTEND TIME Plaintiffs respectfully move for an order extending by four (4) days the time for them to file a response to defendants' motion for summary judgment, until Jan. 28, 2005, and represent: 1. response. Plaintiffs need additional time to prepare their

Case 3:03-cv-00929-AWT

Document 54

Filed 01/24/2005

Page 2 of 3

2.

In recent weeks plaintiffs' counsel has had a pretrial

memo due and has also had to prepare for a trial in a superior court. 3. Plaintiff has been in the hospital and unable to meet

with his attorney. 3. 4. This is the second extension requested. On Jan. 20, 2004, defense counsel, Stuart Brown was

consulted by e-mail and consented to the request for extension. THE PLAINTIFFS NICHOLAS SICINOLFI and THE NICHOLAS-JAMES COMPANY, LLC

BY:_________________________ WILLIAM B. BARNES, ESQ. (CT0268) Rosenstein & Barnes 1100 Kings Hwy. East Fairfield, CT 06824 Tel (203) 367-7922 Fax (203) 367-8110 E-mail [email protected]

2

Case 3:03-cv-00929-AWT

Document 54

Filed 01/24/2005

Page 3 of 3

CERTIFICATION A copy of the foregoing was faxed and mailed postage prepaid, first class mail, on January 21, 2005, to the following persons at the addresses stated: Louis N. George, Esq. Raymond M. Hassett, Esq. Michelle D. Killion, Esq. Hassett & George, P.C. 555 Franklin Ave., Hartford, CT 06114 ___________________________ WILLIAM B. BARNES, ESQ.

3