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

Case 3:03—cv—00373-RNC Document 90 Filed 08/05/2004 Page 1 of 3 l
THE UNITED STATES DISTRICT COURT l
DISTRICT or CONNECTICUT
RICHARD A. MYERS, ETAL. k
,6 *‘ CIVIL ACTION NO.: 3:03-Ci/-00373 (RNC)
l V. I
I
TOWNSHIP or TRUMBULL, ETA;.
Defendant. AUGUST 5, 2004
y MOTION FOR ENLARGEMENT l
{ The defendant, Westfield Shoppingtown Tmmbull ("Westfield"), by its
attorneys, and pursuant to Fed.R.Civ.Pro. 6(b) and D.Conn. L. Civ. R. 7(b), moves
{ this Honorable Court for the entry of an order granting Westfield an extension of ten
I (10) days up to and including August 17, 2004, to file its Reply to the Plaintiffs’
l Memorandum of Law in Opposition to Defendants’ Motion for Summary Judgment,
{ dated July 26, 2004. ln support thereof, Westfield states as follows: }
1. The Plaintiffs filed their Memorandum of Law in Opposition to *
Motion for Summary Judgment on or about July 28, 2004. [
2. Pursuant to Local Rule 7(d), the due date for Westfield’s Reply to I
; Plaintiffs’ Memorandum of Law in Opposition to Motion for Summary Judgment is l
August 7, 2004. l
gg 3. From July 26, 2004 through August 4, 2004, the undersigned counsel
was in trial in the Connecticut Superior Court, Judicial District of New Haven. As a
l result of my trial commitment, I have not had sufficient time to review the plaintiffs' l
I opposition and prepare a Reply to the Plaintiffs’ Memorandum in Opposition.
l l

E Case 3:03—cv—00373-RNC Document 90 Filed 08/05/2004 Page 2 of 3
I
4. This is Westfield’s first request for an extension of the deadline for the
subject reply brief, and Westfield does not bring this motion for purposes of delay. I
5. The undersigned counsel's office has attempted to ascertain the
II position of plaintiffs’ counsel with respect to this motion by leaving a telephone
Ii I
It message with the office of p1aintiff`s' counsel. The undersigned, however, has not
I received a response from plaintiffs' counsel.
* WHEREFORE, Westfield respectfully requests that this Court grant it an
extension to file its reply to the Plaintiffs’ Objection to Motion for Summary I
Judgment to and including August 17, 2004.
i THE DEFENDANT I
I WESTFIELD sHo1>P1NGTowN I
’ UMBULL
· ` E
I ichael . McCormack, ctl 799 I
i Tyler Cooper & Alcorn, LLP
185 Asylum Street, 35th Floor
Hartford, CT 06103
I Tel.; (860) 725-6200
Fax: (860) 278-3802
Email: [email protected] I
I
I I
I l
I I
I
I 2 I

g Case 3:03—cv—00373-RNC Document 90 Filed 08/05/2004 Page 3 of 3 I
@ cERT1F1cAT1oN I
I hereby certify that the foregoing was mailed first class mail, postage prepaid, l
{ to the following counsel and pro-se parties of record on this 5th day of August 2004: i
ii Cynthia H. Hardaway, Esq. E
Hunt, Hamlin & Ridley 2
Military Park Building
60 Park Place, Suite 1602
Newark, NJ 07102 E
Louis N. George, Esq.
Stuart E. Brown
{ Hassett & George [
555 Franklin Avenue E
Hartford, CT 06114 g
l
i , Robert J. Flanagan, Jr., Esq.
Cella, Flanagan & Weber, P.C.
21 Washington Avenue g
P.O. Box 221 1 V V ;
North Haven, CT 06473-0221 ¤ ‘ j A y 1 E A A
A irn ii IVF
M ha T. cCormack
E i
ll 1
Q
1 i
ll
l J