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

Case 3:03-cv-00381-MRK

Document 48

Filed 05/13/2004

Page 1 of 2

UNITED STATES DISTRICT COURT DISTRICT OF CONNECTICUT

TODD LYNCH, Plaintiff v. KATHY MCNAMARA, TIMOTHY BARRY, and FRANK GRIFFIN, in their individual Capacities Defendants

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CIVIL ACTION NO. 3:03CV0381(MRK)

MAY 12, 2004

DEFENDANTS' MOTION FOR EXTENSION OF TIME TO FILE REPLY Pursuant to Local Rule 7(b), state employees Kathy McNamara, Timothy Barry and Frank Griffin, defendants in this action in their individual capacities, hereby move for a brief extension of time, up to and including May 25, 2004, to file their reply brief in support of their motion for summary judgment. The extension of time is necessary because a number of unexpected case responsibilities have been assumed by the undersigned counsel, including coordinating the response to a massive discovery production for the State in a multi-state federal antitrust litigation pending in federal district court for the Northern District of California. The undersigned also has been responsible for responding to a series of large discovery requests from various pharmaceutical company defendants in state fraud claims currently pending before the Complex Litigation Docket in Tolland. The sheer logistics of the various state and federal discovery responses has absorbed an inordinate amount of time and effort, and thus, the undersigned counsel has been unable to adequately address the arguments made in plaintiff's opposition to defendants' motion for summary judgment.

Case 3:03-cv-00381-MRK

Document 48

Filed 05/13/2004

Page 2 of 2

Despite the undersigned counsel's efforts, she was unable to ascertain plaintiff's counsel's views with respect to this motion, but notes that the parties have extended mutual courtesies with respect to extensions of time for prior filings in this matter. DEFENDANTS Kathy McNamara, Timothy Barry and Frank Griffin in their individual capacities RICHARD BLUMENTHAL ATTORNEY GENERAL BY: _______________________________ Clare E. Kindall Assistant Attorney General Federal Bar No. ct13688 55 Elm Street, P.O. Box 120 Hartford, CT 06141-0120 Tel: (860) 808-5020 Fax: (860) 808-5347 [email protected]

CERTIFICATION

I hereby certify that a true and accurate copy of the foregoing Defendants' Motion for Extension of Time to File Reply Brief was served by first-class mail, postage prepaid, in accordance with Rule 5(b) of the Federal Rules of Civil Procedure on this 12th day of May, 2004 to: Sebastian O. DeSantis, Esq. Darren Waggoner, Esq. Sabilia & DeSantis, LLC 247 Shaw Street P.O. Drawer 191 New London, CT 06320 And by interoffice mail to: Mark P. Kindall, AAG Office of the Attorney General 55 Elm Street, 4th floor Hartford, CT 06106 Gilbert Shasha, Esq. 37 Granite Street P.O. Box 1736 New London, CT 06320

_____________________________________ Clare E. Kindall Assistant Attorney General

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