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

Case 3:03-cv-00410-DJS

Document 67

Filed 01/28/2005

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 (MRK)

January 28, 2005

MOTION FOR EXTENSION OF TIME TO FILE REPLY BRIEF Pursuant to L. Civ. R. § 7(b) and § 7(d), the Defendant, ACMI Corporation, respectfully requests an extension of forty-five (45) days within which to file a reply brief to the Plaintiff's Memorandum in Opposition to Motion for Summary Judgment. The Plaintiff's Memorandum was filed on January 21, 2005, making the Defendant's reply brief due on February 4, 2005. With the requested extension, the Defendant's reply brief would be due on March 23, 2005. The requested extension is necessary to respond the lengthy and complicated legal and factual arguments asserted in the Plaintiff's sixty-four (64) page Memorandum of Law. Further, counsel for the Defendant has several dispositive motions due in the coming month in other cases, making this extension necessary. The Defendant notes that the Plaintiff received several extensions of the period within which to file her Memorandum of Law in Opposition to Summary Judgment.

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 67

Filed 01/28/2005

Page 2 of 2

The undersigned has contacted attorney for the Plaintiff, Christine Caulfield, who indicated that she has no objection this motion. This is the Defendant's first Motion for Extension of Time with regard to this deadline. WHEREFORE, the Defendant respectfully requests that its Motion for Extension of Time be granted. 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 28th day of January, 2005, I hereby mailed a copy of the foregoing to: Kathryn Emmett, Esq. Christine Caulfield, Esq. Emmett & Glander 45 Franklin Street Stamford, CT 06901 Jonathan C. Sterling
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One Goodwin Square 225 Asylum Street Hartford, CT 06103 Phone (860) 522-6103 Fax (860) 548-0006 Juris No. 26105

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