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

Case 3:03-cv-00410-DJS

Document 54

Filed 12/07/2004

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IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF CONNECTICUT __________________________________________x HEIDI E. SCHROEDER, : Plaintiff, : : v. : : ACMI CORPORATION, : Defendant. : __________________________________________x CIVIL ACTION NO. 3:03 CV 0410 (MRK)

DECEMBER 6, 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 an 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 December 31, 2004. This is plaintiff's second request for an extension of this deadline. In support of this request, undersigned counsel represents that counsel for plaintiff require additional time to complete plaintiff's memoranda in opposition due to illness and conflicting personal and professional obligations, including personal obligations related to the holiday season. Attorney Christine Caulfield works in the office on a part-time basis only and has been working diligently to finalize plaintiff's memoranda, but has been delayed due to personal and family illness. In addition, counsel for plaintiff have had and/or will have to meet various obligations in other matters including but not limited to: discovery obligations in Clark v. Vermont Pure Holdings, Ltd., et al., 3:02 CV 2278 (RNC), which is subject to a January 15, 2005

Case 3:03-cv-00410-DJS

Document 54

Filed 12/07/2004

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discovery deadline; obligations relating to pro bono representation of the plaintiff in Delise v. Deboo, et al., 3:03 CV 382 (JCH)(HBF), at the request of the Honorable U.S. District Court Judge Janet C. Hall, including preparation of a memorandum in opposition to the government's response to the Amended Petition for Habeas Corpus; preparation of a post-trial memorandum in 83-85 Railroad Avenue, et al v. Samuel Judice, M.D., et al., CV 01 0186514S, pending in Connecticut Superior Court; attendance at several depositions in the cases, Roe v. Burden, et al., CV 02 0396666S, Doe v. Derma Clinic, et al., CV 01 0382381S and Allen v. Burden, et al., CV 01 0384425S, all pending in Connecticut Superior Court; obligations relating to the resolution of Robles v. USA, et al., 3:01 CV 1659 (AVC) and Montauredes v. Hooper Holmes, Inc., et al., 3:03 CV 1344 (DJS); and obligations on behalf of the Center for Children's Advocacy. In addition, undersigned counsel is scheduled to be away visiting family for two weeks over the holiday season. Attorney Jonathan Sterling, who represents the defendant in this action, does not object to this motion. This action has not been assigned for trial.

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Case 3:03-cv-00410-DJS

Document 54

Filed 12/07/2004

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THE PLAINTIFF, HEIDI E. SCHROEDER

BY: KATHRYN EMMETT Emmett & Glander 45 Franklin Street Stamford, CT 06901 (203) 324-7744 Federal Bar No. cT ct05605 [email protected] CERTIFICATION This is to certify that a copy of the foregoing was mailed, postage prepaid, this 6th 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

Kathryn Emmett

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