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

Case 3:03-cv-00410-DJS

Document 52

Filed 11/08/2004

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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)

NOVEMBER 5, 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 thirty day 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 8, 2004. This is plaintiff's first request for an extension of this deadline. In support of this request, undersigned counsel represents that she requires additional time to complete plaintiff's memoranda in opposition due to conflicting personal and professional obligations, including but not limited to preparation for and attendance at a settlement conference in Clark v. Vermont Pure Holdings, Ltd., et al., 3:02 CV 2278 (RNC) on October 20, 2004 and discovery obligations in Clark, which is subject to a January 15, 2005 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,

Case 3:03-cv-00410-DJS

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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; preparation of an appellate brief to the Second Circuit Court of Appeals concerning insurance coverage in Northfield Insurance Company v. Derma Clinic, Inc., 04-2056-cv (L) and Northfield Insurance Company v. Derma Clinic, Inc., 04-2057-cv (CON) due November 10, 2004; and attendance at several depositions in the cases underlying the appeal, 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. Attorney Christine Caulfield, who also represents the plaintiff, only works in the office on a part-time basis and has also been working on the above-referenced obligations and, in particular, the appellate brief to the Second Circuit. Undersigned counsel is authorized to represent that 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 52

Filed 11/08/2004

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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 5th day of November, 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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