Free Motion for Extension of Time - District Court of Connecticut - Connecticut

Case 3:03-cv-00386-AWT

Document 66

Filed 08/05/2005

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UNITED STATES DISTRICT COURT DISTRICT OF CONNECTICUT

EUNICE SMITH, Plaintiff v. STATE OF CONNECTICUT, DEPARTMENT OF CORRECTION, ET AL. Defendants

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CIVIL ACTION NO. 3:03CV0386(AWT)(DFM)

August 5, 2005

MOTION FOR EXTENSION OF TIME TO FILE DISPOSITIVE MOTIONS

The defendants, through counsel, respectfully request an extension of time of ninety (90) days after an arbitrator makes a decision regarding the plaintiff's request for reinstatement that is currently pending. In support of this motion, the defendants represent as follows: 1. The current Scheduling Order has set the deadline for filing dispositive

motions for August 9, 2005 (Doc. # 65). 2. The parties had a settlement conference with Magistrate Judge Martinez on

June 9, 2005. The conference included discussion regarding the plaintiff's grievance and arbitration of her dismissal that is currently pending an arbitrator's ruling. 3. The arbitrator's decision is imminent and that determination likely will

have an effect upon this current action that is before this court. 4. The parties have agreed to continue settlement discussions after receipt of

the arbitrator's ruling. If the case can be settled, and to avoid an unnecessary expenditure

Case 3:03-cv-00386-AWT

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of needless time on the part of all parties and the court, the defendants respectfully request the extension of time. 5. Additionally, the file in the above-captioned matter is voluminous and,

inasmuch as it entails several years of litigation, additional time is required to review and compile material. 6. judgment. 7. Pursuant to Local Rule 7(b), the undersigned discussed this extension with This is defendants' second request for an extension of time to file summary

plaintiff's counsel, Cynthia Jennings, Esq., at the settlement conference and Attorney Jennings indicated that she has NO OBJECTION to this motion. WHEREFORE, the defendants respectfully request an order extending the deadline for filing dispositive motions for ninety (90) days after the arbitrator makes a ruling on plaintiff's current grievance regarding her termination.

DEFENDANTS STATE OF CONNECTICUT, DEPARTMENT OF CORRECTION, ET AL RICHARD BLUMENTHAL ATTORNEY GENERAL

BY:

______________________________ Jane B. Emons Assistant Attorney General Federal Bar No. 16515 55 Elm Street - P.O. Box 120 Hartford, CT 06141-0120 Tel: (860) 808-5340 Fax: (860) 808-5383 Email: [email protected]

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Case 3:03-cv-00386-AWT

Document 66

Filed 08/05/2005

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CERTIFICATION

I hereby certify that a copy of the foregoing Motion for Extension of Time to File Dispositive Motions was mailed this prepaid to: Cynthia Jennings, Esq. The Barrister Law Group 211 State Street, 2nd Floor Bridgeport, CT 06604 5th day of August, 2005, first class postage

___________________________ Jane B. Emons Assistant Attorney General

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