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

Case 3:03-cv-00386-AWT

Document 74

Filed 01/20/2006

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UNITED STATES DISTRICT COURT
DISTRICT OF CONNECTICUT __________________________________________ EUNICE SMITH : Plaintiff : : V. : : : STATE OF CONNECTICUT, : DEPARTMENT OF CORRECTIONS, ET AL : Defendant. : __________________________________________: CIVIL ACTION NO. 303CV00386(AWT)

January 17, 2006

MOTION TO EXTEND PLAINTIFF'S TIME TO RESPOND TO DEFENDANT'S MOTION FOR SUMMARY JUDGMENT Pursuant to Local Rule of Civ. P. the plaintiff seeks leave of the Court to extend the time within which to respond to defendant's Motion for Summary Judgment, currently due January 20th 2006 to February 20th 2006. Plaintiff has good cause for requesting this second extension. Specifically the press of legal business, related to Appellate Court briefs and hearings, administrative hearings and responses to several Summary Judgment Motions all of which come due around the same time as the Smith response. Summary Judgment responses are due on: Edwards v. Metro North Railroad Co., Presilus Prophete v. Ed Mitchell, Assegai v. Town of Bloomfield, et al., Richardson v. State of Connecticut, et al., Bogle-Assegai v. State of Connecticut, et al., Hassell v. Town of Manchester, King v. State of Connecticut, Barlow v. City of Hartford.

Case 3:03-cv-00386-AWT

Document 74

Filed 01/20/2006

Page 2 of 3

Plaintiff contacted defendant's counsel prior to the submission of this request and was told in no uncertain terms to represent defendant's vehement objection to this request. ORAL ARGUMENT NOT REQUESTED TESTIMONY NOT REQUIRED Respectfully submitted, PLAINTIFF By: /S/___________________ Cynthia R. Jennings, Esq., The Barrister Law Group, LLC., 211 State Street, 2nd Floor Bridgeport, Ct 06604 Tel: 203-334-4800 Email: [email protected]

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Case 3:03-cv-00386-AWT

Document 74

Filed 01/20/2006

Page 3 of 3

CERTIFICATION This is to certify that the foregoing Motion for leave to respond to defendant's Motion for Summary Judgment, was served on defendant's counsel and all pro se parties, as shown below, on this 17H of January 2006, via regular U.S. mail. Jane B. Emons Assistant Attorney General OFFICE OF THE ATTORNEY GENERAL State of Connecticut 55 Elm Street ­ P.O. Box 120 Hartford, CT 06141-0120

/S/_____________________ Cynthia R. Jennings, Esq.,

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