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

Case 3:03-cv-00410-DJS Document 56 Filed 12/29/2004 Page 1 of 3
IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF CONNECTICUT

HEIDI E. SCHROEDER, : CIVIL ACTION NO.
Plaintiff, : 3:03 CV 0410 (MRK)
v.
ACMI CORPORATION,
Defendant. : DECEMBER 27, 2004

MOTION FOR EXTENSION OF TIME
Pursuant to Rule 7(b) of the Local Rules of Civil Procedure of the United States District
Court for the District of Connecticut, plaintiff respectfully requests that the Court grant plaintiff a
three week extension of time within which to file her memorandum in opposition to Defendant’s
Motions for Summary Judgment and to Preclude Testimony filed October 18, 2004 up to and
including January 21, 2004 due to prolonged illness of plaintiffs counsel and her family and
other circumstances as set forth below. This is plaintiff’s third request for an extension of this
deadline.
In support of this request, tmdersigned counsel represents that Attorney Christine
Caulfield, who represents plaintiff in this action, has been working diligently to complete
plaintiffs memoranda, but has been unable to do so as of this time due to several weeks of
severe illness of counsel and her two small children. Undersigned counsel, who also represents
plaintiff in this action, has been unable to devote considerable time to plaintiffs memoranda due
to a scheduled family vacation and conflicting professional obligations including discovery

Case 3:03-cv-00410-DJS Document 56 Filed 12/29/2004 Page 2 of 3
obligations in Clark v. Vermont Pure Holdings, Ltd., et al., 3:02 CV 2278 (RNC), which is
subject to a January 15, 2005 discovery deadline; obligations relating to pro bono representation
of Sammie Goss at the request of the Honorable U.S. District Court Judge William I. Garfinkel;
preparation for complex mediation in Bolton v. Weil, Gotshal & Manges LLP, et al., Index No.
602341/03, pending in the Supreme Court of the State of New York, County of New York;
preparation of a post-trial memorandum in 83-85 Railroad Avenue, et al v. Samuel Judice, M.D.,
gg, CV 01 01865148, pending in Connecticut Superior Court; discovery and other obligations
in Roe v. Burden, etal., CV 02 0396666S, Doe v. Derma Clinic, et al., CV 01 03 82381S and
Allen v. Burden, et al., CV 01 03 84425S, all pending in Connecticut Superior Court; obligations
relating to the resolution of Robles v. USA, et al., 3:01 CV 1659 (AVC); and obligations on
behalf ofthe Center for Children”s Advocacy. In addition, counsel do not have support staff in
the office this week due to scheduled vacations. Counsel require three additional weeks to
complete the memoranda because Attorney Caulfield continues to be ill and requires a short
period to rest and recuperate. In addition, both counsel have family obligations relating to the
holidays.
Attorney Jonathan Sterling, who represents the defendant in this action, has authorized
undersigned counsel to represent that defendant does not object to extensions of time for filing
plaintiffs memoranda provided the memoranda are filed prior to March 1, 2005. This action has
not been assigned for trial.
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Case 3:03-cv-00410-DJS Document 56 Filed 12/29/2004 Page 3 of 3
THE PLAINTIFF, HEIDI E. SCHROEDER
BY. T
THR MMETT
mmett & Glander
45 Franklin Street
Stamford, CT 06901
(203) 324-7744
Federal Bar No. cT ct05605
kemmettftlemmettandglandercom
CERTIFICATION
This is to certify that a copy ofthe foregoing was mailed, postage prepaid, this 27"‘ day of
December, 2004, to:
James M. Sconzo, Esq.
Jonathan C. Sterling, Esq.
Halloran & Sage, LLP
One Goodwin Square, 225 Asylum Street
Hartford, CT 06103.4303
g (lj l
athryn Em ett
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