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

Case 3:03-cv-00372-AVC

Document 66

Filed 06/01/2007

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UNITED STATES DISTRICT COURT DISTRICT OF CONNECTICUT

KELLY PHANEUF, Plaintiff, v. ROSE MARIE CIPRIANO, DORENE M. FRAIKIN, KATHLEEN BINKOWSKI, TOWN OF PLAINVILLE and PLAINVILLE BOARD OF EDUCATION, Defendants.

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Civil No. 3:03CV00372 (AVC)

JUNE 1, 2007

MOTION FOR ENLARGEMENT OF TIME WITHIN WHICH TO FILE MEMORANDUM IN OPPOSITION TO MOTION FOR SUMMARY JUDGMENT Pursuant to Federal Rules of Civil Procedure 6 (b) and Local Rule 7 (b), the plaintiff, Kelly Phaneuf, respectfully requests that the Court grant her an extension of an additional thirty (30) days, within which to file her Memorandum in Opposition to Defendants' Motion for Summary Judgment. The defendants' motion for summary judgment was filed with this Court on May 18, 2007. The plaintiff respectfully requests an additional thirty (30) days from the current deadline of June 8, 2007, until July 9, 2007, within which to file her Memorandum in Opposition to Defendants' Motion for Summary Judgment.

ORAL ARGUMENT NOT REQUESTED TESTIMONY NOT REQUIRED

Case 3:03-cv-00372-AVC

Document 66

Filed 06/01/2007

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Plaintiff's counsel requests this extension because the undersigned is currently involved with trial preparation in light of a trial scheduled to commence in June, 2007 in New Haven Superior Court; because plaintiff's counsel needs additional time to adequately research the issues raised in the defendants' motion for summary judgment in order to respond to the motion; and because plaintiff's counsel will be traveling out of state prior to the current deadline within which to respond to said motion for summary judgment. Accordingly, plaintiff's counsel needs the additional time in order to respond to the instant motion for summary judgment. This is the first motion for enlargement of time being filed by the plaintiff with respect to the instant motion for summary judgment. Opposing counsel has been contacted and there is no objection to this request. WHEREFORE, the plaintiff respectfully requests that the Court grant her motion for enlargement of time.

THE PLAINTIFF, KELLY PHANEUF

By:___/s/___________________________________ Sheila J. Hall (ct 22566) Gesmonde, Pietrosimone & Sgrignari, L.L.C. 3127 Whitney Avenue Hamden, CT 06518-2344 (203) 407-4200

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Case 3:03-cv-00372-AVC

Document 66

Filed 06/01/2007

Page 3 of 3

ORDER The foregoing motion having come before me, it is hereby ORDERED: GRANTED / DENIED.

Judge/Clerk

CERTIFICATION This is to certify that a copy of the foregoing was electronically filed, and mailed, via first class, postage prepaid, this 1st day of June, 2007 to: James G. Williams, Esq. Williams, Walsh & O'Connor, LLC 110 Washington Avenue, Second Floor North Haven, CT 06473

/s/ Sheila J. Hall

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