Free Motion for Extension of Time - District Court of Connecticut - Connecticut

Case 3:03-cv-00369-DJS

Document 39

Filed 05/18/2004

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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)

May 17, 2004

DEFENDANTS' UNOPPOSED MOTION FOR FIVE DAY EXTENSION OF TIME TO FILE DISPOSITIVE MOTION PLEASE TAKE NOTICE that the Defendants, UST Inc. and Mark Uliasz, hereby respectfully request that this Court grant them an extension of time of five (5) days, or through and including Monday, May 24, 2004, by which to file their Motion for Summary Judgment. The reason for this request is that one of the attorneys sharing a significant portion of responsibility for completing the Motion and accompanying Memorandum of Law, Steven Younes, must leave the state for several days due to the unexpected death of a close family member. It would therefore present a hardship for another attorney to become familiar with the case and the status of these pleadings, and to thus assist the undersigned in timely completing the submission. This is the second request for an extension by Defendants as to this particular time limitation. The prior request was for two weeks until April 15, 2004 as a result of Plaintiff's extension of the discovery deadline. There were three prior requests for an extension of time of the discovery deadline, which resulted in the extension of this deadline. Plaintiff's counsel has no objection to the granting of this Motion.

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Case 3:03-cv-00369-DJS

Document 39

Filed 05/18/2004

Page 2 of 3

WHEREFORE, the Defendants, UST Inc. and Mark Uliasz, respectfully request that this Court grant them an extension of time for five (5) days, or through and including May 24, 2004, within which to file their Motion for Summary Judgment.

EPSTEIN BECKER & GREEN, P.C. Attorneys for Defendants

By: Mary A. Gambardella, Esq. Federal Bar No. ct05386 One Landmark Square, Suite 1800 Stamford, CT 06901-2601 (203) 348-3737

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Case 3:03-cv-00369-DJS

Document 39

Filed 05/18/2004

Page 3 of 3

CERTIFICATION The undersigned hereby certifies that a copy of Defendants' Motion for Extension of Time to File Motion for Summary Judgment was mailed, postage prepaid, this 17th day of May 2004 to: Scott R. Lucas, Esq. Martin, Lucas & Chioffi, LLP 177 Broad Street Stamford, Connecticut 06901

_________________________________________ Mary A. Gambardella

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