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

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{ Case 3:03-cv—OO369—DJS Document 37 Filed O4/28/2004 Page 1 of 3
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J IN THE UNITED STATES DISTRICT COURT “ ` ‘`'; .
l FOR THE DISTRICT OF CONNECTICUT
Zilllli APH 28 A lb- bb
l LYNN B. KANIOS : Civil Action N0. 303CY3§9_fDtIS)_ __ .
, , u.5>._ r..sg;rlj·:l§'i Ciflltii
Plaintifi; : iélhilt I l` Util]: C
vs.
UST INC. and MARK ULIASZ,
Defendants. April 27, 2004
l DEFENDANTS’ MOTION FOR EXTENSION OF
j TIME TO FILE DISPOSITIVE MOTION
i PLEASE TAKE NOTICE that the Defendants, UST Inc. and Mark Uliasz, hereby
I respectfully request that this Court grant them an extension of time of two weeks, or through and
including May 1'9, 2004, by which to file their Motion for Summary Judgment.
The primary reason for this request is that Plaintiff just obtained an extension of time
through April 15, 2004, so that Defendants would be compelled to respond to Interrogatories and
Requests for Production served in mid—March. The prior deadline for filing of a dispositive
motion was May Sth, or thirty (30) days after the prior deadline for the close of discovery-April
Sth. As the discovery deadline was just moved to April 15th, Defendants respectfully request a
similar extension with respect to the deadline for filing of a Motion for Summary Judgment. I
Second, the undersigned counsel needs this additional time to adequately include in
Defendants’ Motion for Summary Judgment any potential new arguments which they should
raise, or which it is anticipated Plaintiff could raise, in connection with the most recent discovery
responses and production. O
Plaintiffs counsel has no objection to the granting of this Motion. l
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l Case 3:03-cv—OO369—DJS Document 37 Filed O4/28/2004 Page 2 of 3
I This is the third request for an extension of time in this case, but the iirst with respect to
addressing only this particular time limitation so as to match the extended discovery deadline.
WHEREFORE, the Defendants, UST Inc. and Mark Uliasz, respectfully request that ,
' this Court grant them an extension of time through and including May 19, 2004, within which to
tile their Motion for Summary Judgment.
I EPSTEIN BEC & GREEN, P.C.
l Attorneys for D fen ants
i ..4
By: g ‘
Steven J. Youn s, Esq.
Federal Bar N ctl2408
One Landmark Square, Suite 1800
Stamford, CT 06901-2601 0
(203) 348-3737
ST:28488v1 ` " 2 ' }

{ Case 3:03-cv—OO369—DJS Document 37 Filed O4/28/2004 Page 3 of 3
CERTIFICATION
li The undersigned hereby certifies that a copy of Defendants’ Motion for Extension of Time
y to File Motion fer Summaiy Judgment was mailed, postage prepaid, this 27th day of April 2004 to: I
l Scott R. Lucas, Esq.
Martin, Lucas & Chiofti, LLP
` 177 Broad Street
Stamford, Connecticut 06901
74 Q Steven J. Younes
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