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

Case 3:03-cv-00386-AWT

Document 83

Filed 03/29/2006

Page 1 of 3

United States District Court
DISTRICT OF CONNECTICUT EUNICE SMITH, Plaintiff v. STATE OF CONNECTICUT, DEPARTMENT OF CORRECTION, ET AL. Defendants : : : : : : : : : CIVIL ACTION NO. 3:03-cv-00386(AWT)

March 28, 2006

MOTION TO EXTEND PLAINTIFF'S TIME TO RESPOND TO DEFENDANT'S REPLY MEMORANDUM TO PLAINTIFF'S RESPONSE TO DEFENDANTS' MOTION FOR SUMMARY JUDGMENT Pursuant to Rule 9(b)(1) of the Local Rules of Civil Procedure, Plaintiff hereby requests that the deadline for Plaintiff's response to Defendant's Reply Memorandum to Plaintiff's Response to Defendants' Motion for Summary Judgment be extended for an additional twenty-one days, from March 22, 2006 to April 22, 2006. This extension of time is necessitated by: (1) the press of legal business related to a Motion to Dismiss response on the following federal case, Presilus Prophete v. Ed Mitchell, Inc.

(3:05CV00912 WWE); as well as the writing of one Appellate brief and preparing for one Appellate argument, in the following cases of Femi Bogle-Assegai v. State of Connecticut, Commission on Human Rights and Opportunities (302CV02292HBF) and Leonyer Richardson v. State of Connecticut, Et al , (3:02CV00625AVC).
Cynthia R. Jennings, Esq.,

THE BARRISTER LAW GROUP, LLC.,
211 State Street, 2nd Floor ~ Bridgeport ~ CT 06604 Tel: 203-334-4800 ~ Fax: 203-368-6985 Federal Bar No. CT21797

Case 3:03-cv-00386-AWT

Document 83

Filed 03/29/2006

Page 2 of 3

This is plaintiff's first request for extension to file a response to Defendant's Reply Memorandum to Plaintiff's Response to Defendants' Motion for Summary Judgment. Plaintiff's counsel contacted counsel for Defendant who has consented to the requested extension. ORAL ARGUMENT NOT REQUIRED TESTIMONY NOT REQUIRED PLAINTIFF _________________________________ CYNTHIA R. JENNINGS, ESQ.,
THE

BARRISTER LAW GROUP,

LLC.,

211 STATE STREET, BRIDGEPORT CONNECTICUT 06604 TEL: 203-334-4800 FAX: 203-333-7178

Email: [email protected] Federal Bar No. CT21797

Cynthia R. Jennings, Esq.,

THE BARRISTER LAW GROUP, LLC.,
211 State Street, 2nd Floor ~ Bridgeport ~ CT 06604 Tel: 203-334-4800 ~ Fax: 203-368-6985 Federal Bar No. CT21797

Case 3:03-cv-00386-AWT

Document 83

Filed 03/29/2006

Page 3 of 3

CERTIFICATE OF SERVICE
I hereby certify that on March 28, 2006, a copy of foregoing Plaintiff's Extension of Time to Respond to Defendant's Reply Memorandum to Plaintiff's Response to Defendants' Motion for Summary Judgment was sent by regular U.S. Mail to the following Counsel of Record:

Jane B. Emons Assistant Attorney General 55 Elm Street-P. O. Box 120 Hartford, CT 06141-0120

___________________________________ CYNTHIA R. JENNINGS, ESQ.,

Cynthia R. Jennings, Esq.,

THE BARRISTER LAW GROUP, LLC.,
211 State Street, 2nd Floor ~ Bridgeport ~ CT 06604 Tel: 203-334-4800 ~ Fax: 203-368-6985 Federal Bar No. CT21797