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

Case 3:03-cv-00369-DJS

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Filed 07/27/2004

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IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF CONNECTICUT LYNN B. KANIOS Plaintiff, vs. UST INC. and MARK ULIASZ, Defendants. : : : : : : : : : Civil Action No. 303CV369 (DJS)

July 23, 2004

MOTION FOR EXTENSION OF TIME TO FILE REPLY Pursuant to Federal Rules of Civil Procedure 6(b) and Local Rules of Civil Procedure 9(b)3, the Defendants in the above-captioned matter hereby respectfully move for a three (3) week extension of time or until August 19, 2004, to file a reply to Plaintiff's Opposition to Defendants' Motion for Summary Judgment. In support of good cause for the granting of this motion, counsel submits the following: 1. 2. Defendants filed their Motion for Summary Judgment on May 21, 2004. On or about July 12, 2004, Plaintiff filed her Opposition to Defendants' Motion

for Summary Judgment. Thus, Defendants' reply to Plaintiff's Opposition is currently due July 29, 2004. 3. Defendant respectfully requests a three (3) week extension of time to file said

reply. The additional time is necessary in light of various unrelated client commitments and scheduling conflicts. The additional time is also necessary to ensure in-house counsel for UST is provided with sufficient time to review said reply. 4. been made. No prior request for extending the time to file a reply to Plaintiff's Opposition has

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Case 3:03-cv-00369-DJS

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5. this request.

Scott Lucas, Esq., counsel for Plaintiff, has no objection to the Court's granting of

WHEREFORE, the Defendants respectfully request that this motion be granted, extending the deadline to file a reply to Plaintiff's Opposition to Defendants' Motion for Summary Judgment by three (3) weeks, or until August 19, 2004. THE DEFENDANTS, By: ________________________________ Steven J. Younes Federal Bar No. ct12408 Epstein Becker & Green, P.C. One Landmark Square, Suite 1800 Stamford, CT 06901 Counsel for Defendant

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Case 3:03-cv-00369-DJS

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Filed 07/27/2004

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CERTIFICATION The undersigned hereby certifies that a copy of the foregoing Motion to Extend Time was sent via first class mail, postage prepaid, this 23rd day of July, 2004 to counsel of record for the plaintiff as follows: Scott R. Lucas, Esq. Martin, Lucas & Chioffi, LLP 177 Broad Street Stamford, Connecticut 06901

_________________________________________ Steven J. Younes

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