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

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Case 3:03-cv—OO373—RNC Document 85 Filed 07/O2/2004 Page 1 of 4
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(HUNT, HAMLIN, & RIDLEY (
Military Park Building
60 Park Place, Suite 1602 ?
(Newark, New Jersey 07102 ‘
(973) 242-4471 i ,
Attorney(s) for P1ainti£f(s) 5 1
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RICHARD A. MYERS, SHERNETTE {UNITED STATES DI TRICT COURT I
CLARK, KENNETH BINGHAM, FLOYD { DISTRICT OF CO CTICUT
Mamas { i
Plaintiffs, 5 Q I
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TOWNSHIP OF TRUMBULL, E CASE NO. :3:03 CV§373 {RNC)
OFFICER COPPOLA, LD. # 24 { Q
(first name unknown) E ij; ·:£ “
(individually and in his E ·"" um
official capacity), OFFICER, { § _,____
I.D. #35 (name unknown) E { g""‘“'
qimuviauaiiy ana in his { {gag; M EW {
official capacity), { 5*9** `(j {
SPECTAGUARD, MICHAEL (last { Qcug K-, @ {
name unknown) , WESTFIELD Q Q
SHOPPINGTOWN, JOHN DOES 1 { —~—a w i
through 10, JANE DOES 1 E i
through 10, and ABC Corp. Q ; ~
through XYZ, individually, { { i
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gointly and severally, g _
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Defendants. E July lr {2004 {
ION FOR ENLAR NT F TIME TO FILE PE NTIFFS'
RES.NE TODE NDAN'1"MOTINFORStJbdb¢ARJ1ID T
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Plaintiffs Richard Meyers, Shernette dlark, Kenneth
Bingham, and Floyd McLean, hereby move for an Enlargement of
Time of twenty—-one (21) days from July 5, @004, for the
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filing of responses to defendants Westfield Shoppingtown
Trumbull, Spectaguard Acquisitions, and Town of Trumbull, y
Officer Coppola, and Officer Leos (ID #35) , seiparate motions
for summary judgment. Plaintiffs? responsesi to defendant
Town of Tr\;;nbull's motion for summary judgment; are presently %
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_ · Case 3:03-cv—OO373—RNC Document 85 Filed 07/O2/2(TO4 Page 2 of 4
due July 5, 2004. Plaintiffs' responses? to defendant
Westfield.Shoppingtown.Trumbull's motion for sdmmary judgment
are presently due July 9, 2004. Both of defenpants' motions 2
were received by my office on June l7, 20d4. Defendant E
Spectaguard's motion for summary judgment waséreceived by my I
office on September 23, 2004. As of this date, I have not E
been notified.by e—mail from the Court regarding the due date
for plaintiffs’ responses to defendant Spectagpard's motion. 7
Plaintiffs request a twenty—one—day enladgement of time i
for the following reasons: E
l. Throughout the course of the discovery peridd, plaintiffs'
noticed the Township of Trumbull defendants fpr depositions
on several different dates. Due to the unayailability of
witnesses and defense oounsels’ scheduling eonflicts, the I
Township of Trumbull defendants were not ischeduled for J
depositions until June 22, 2004. E
On June 21, 2004, I received confirmatioh from counsel i
for the Township of Trumbull that the depositions would not j
go forward due to another defense counsel’s uhavailability. E
I attempted to rescheduled said depositions fbr dates prior j
to plaintiffs' due dates for responses to defemdants’ motions
for summary judgment. However, the first ivailable date
provided by defense counsel was July 15, 2004; which is well
after the due date for plaintiffs' responses,. This date was
not provided to me until June 29, 2004. Q i
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. Case 3:03-cv-00373-RNC Document 85 Filed 07/O2/ZQO4 Page 3 of 4 I
If my request for an enlargement of timd is granted, I I
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anticipate completing the necessary·depositions for inclusion
in p1aintiffs' summary judgment responses. ;
2. There are three different due dates fdr plaintiffs' I
responses for summary judgement. The last motion for summary
judgment was not received by my office until§June 23, 2004.
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In order to avoid having to file three separate memorandums
of law and accompanying exhibits for each memorandum, I am
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requesting an enlargement of time so that I can file one -
brief and one set of exhibits with respect to all defendants. Q
If plaintiffs’ request is granted thegnew date for E
plaintiffs' responses would be July 26, 2004I Counsel for
defendants have been consulted and have no objections to this I
Motion. This is plaintiffs’ first request fo? an extension I
time to file responses to summary judgmentimotions. Each
defense counsel requested an extension of time to file their
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respective motion for summary judgments. I
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BY ·— - ¤‘%—‘é.··'.Z:.'·'·¥'·?.-"
Cyn“hi H._Hardaway Esq. I
Fed. =;;)Nb.: CT2§752 I
» Hunt, Hamlhn & Ri¤1=y I
Military `Eark Buil ing {
60 Park Place, 16* Floor
Newark, Neh Jersey 07102 I
(973) 242{447l y
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. - Case 3:03-cv—OO373—FiNC Document 85 Filed 07/O2/2(jO4 Page 4 of 4
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QERTIFICATIQN QF MAILING
This is to certify that, on this lst day of July 2004, an original anti one copy ofthe
foregoing has been sent via overnight mail to the Clerk of the United States District Court and via i
regular mail to the following counsel ofrecord: i
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Stuart E. Brown j f
Hasset & George, P.C. i
555 Franklin Avenue
Hartford, Connecticut 06114
Michael T. McCormack:
Tyler, Cooper & Alcorn, LLP Q
ISS Asylum Street i
Cityplace I 35*** Floor 2
Hartford, CT 06103-3802 Q ,
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Robert J. Flanagan, Jr. E
Celia, Flanagan & Weber, P.C. ,
2i Washington Avenue
P.O. Box 221 :
North Haven, CT 06473-0221 I
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DATED: July 1, 2004
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