Free Motion for Leave to File - District Court of Connecticut - Connecticut

Case 3:03-cv-00410-DJS

Document 72

Filed 03/18/2005

Page 1 of 2

UNITED STATES DISTRICT COURT DISTRICT OF CONNECTICUT HEIDI E. SCHROEDER, Plaintiff, VS. ACMI CORPORATION, Defendant. : : : : : : : CIVIL ACTION NO. 3:03CV 0410 (DJS)

MARCH 18, 2005

MOTION FOR PERMISSION TO FILE OVERSIZED BRIEF ACMI Corporation ("ACMI") respectfully requests the Court's permission to file a Reply Memorandum of Law in Further Support of Motion for Summary Judgment, that exceeds the ten-page limit set by District of Connecticut Local Rule 7(d). Specifically, ACMI requests permission to file a Reply Memorandum that is twenty-five (25) pages in length. In support of this Motion, ACMI sets forth as follows: ACMI's Memorandum in Support of Motion for Summary Judgment totaled thirty-six (36) pages, less than the forty (40) pages permitted under Local Rule 7(a). Plaintiff then submitted a sixty-three (63) page Memorandum in Opposition to Motion for Summary Judgment ("Plaintiff's Memo"). ACMI consented to her motion to file that oversized brief. Plaintiff's Memo and her twenty-one (21) page Rule 56(a)(2) Statement raise numerous issues and legal arguments, all of which ACMI should be permitted to reply to. The fifteen (15) additional pages being sought are necessary to reply to the plaintiff's arguments, to distinguish the cases she cites, and to clarify exactly what material facts are not in dispute. Notably, the additional pages being requested are significantly fewer than the number that were allowed to the plaintiff in her Memo (twenty-three (23) pages over the limit).

One Goodwin Square 225 Asylum Street Hartford, CT 06103

Phone (860) 522-6103 Fax (860) 548-0006 Juris No. 26105

Case 3:03-cv-00410-DJS

Document 72

Filed 03/18/2005

Page 2 of 2

The undersigned has contacted attorney for the plaintiff, Kathryn Emmett, Esq., and Attorney Emmett has not objection to this motion. This is the first time in this case that ACMI has requested to make an oversized filing. WHEREFORE, ACMI respectfully requests that the Court grant its Motion and permit ACMI to file an oversized Reply Memorandum of Law in Further Support of Motion for Summary Judgment. THE DEFENDANT: ACMI CORPORATION

By

James M. Sconzo Fed Bar # ct04571 and Jonathan C. Sterling Fed Bar # ct24576 of HALLORAN & SAGE LLP One Goodwin Square 225 Asylum Street Hartford, CT 06103 (860) 522-6103

CERTIFICATION This is to certify that on this 18th day of March, 2005, I hereby mailed a copy of the foregoing to: Kathryn Emmett, Esq. Christine Caulfield, Esq. Emmett & Glander 45 Franklin Street Stamford, CT 06901 James M. Sconzo
665389

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One Goodwin Square 225 Asylum Street Hartford, CT 06103 Phone (860) 522-6103 Fax (860) 548-0006 Juris No. 26105