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

Case 3:03-cv-00369-DJS

Document 42

Filed 06/07/2004

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UNITED STATES DISTRICT COURT DISTRICT OF CONNECTICUT LYNN B. KANIOS Plaintiff, V. UST, INC. and MARK ULIASZ Defendants. : : : : : : : : : CIVIL ACTION NO.: 303 CV 369 (DJS)

JUNE 4, 2004

PLAINTIFF'S UNOPPOSED MOTION FOR EXTENSION OF TIME Plaintiff Lynn B. Kanios hereby moves for an extension of 30 days, from June 11, 2004 to July 12, 2004, in which to file her responsive brief to defendants' Motion for Summary Judgment filed in this action. In support of this Motion, plaintiff submits the following: 1. On or about April 28, 2004, defendants moved for an extension of time to and

including May 19, 2004 in which to file their motion for summary judgment, which motion was granted. 2. On or about May 18, 2004, defendants moved for an additional extension of time

to and including May 24, 2004 in which to file their motion for summary judgment, which motion was granted. 3. Under the current schedule, plaintiff's responsive brief to the motion for summary

judgment is due June 11, 2004. 4. Due to the travel plans of plaintiff's counsel, this additional time is needed to

draw together the necessary information in which to adequately prepare plaintiff's response. This is the first request for an extension by plaintiff as to this particular limitation. 5. Defendants' counsel has no objection to the granting of this Motion.

Case 3:03-cv-00369-DJS

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Filed 06/07/2004

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WHEREFORE, plaintiff respectfully request that this Motion to Extend be granted.

By

___________________________ Scott R. Lucas (CT00517) Michel Bayonne (CT24628) Attorneys for Lynn B. Kanios Martin Lucas & Chioffi, LLP 177 Broad Street Stamford, CT 06901 Phone: (203) 973-5200 Fax: (203) 973-5250 [email protected] [email protected]

Case 3:03-cv-00369-DJS

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Filed 06/07/2004

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CERTIFICATE OF SERVICE This is to certify that on this 2nd day of June 2004, the foregoing was mailed, first class, postage prepaid, to: Steven J. Younes, Esq. Mary A. Gambardella, Esq. Epstein, Becker & Green, P.C. One Landmark Square Stamford, Connecticut 06901-2681 Phone: (203) 348-3737

_________________________ Scott R. Lucas