Free Motion for Leave to File - District Court of Connecticut - Connecticut

Case 3:01-cv-02189-SRU

Document 56

Filed 03/05/2004

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UNITED STATES DISTRICT COURT DISTRICT OF CONNECTICUT MICHELLE MARTIN, Plaintiff, v. DUPONT FLOORING SYSTEMS, INC. and DUPONT COMMERCIAL FLOORING SYSTEMS, INC., Defendants. : : : : : : : : : : :

CIVIL ACTION NO. 301CV02189 (SRU)

MARCH 2, 2004

DEFENDANTS' MOTION FOR PERMISSION TO FILE A SECOND SUPPLEMENTAL MEMORANDUM IN SUPPORT OF THEIR MOTION FOR SUMMARY JUDGMENT During the course of oral argument on Defendants' Motion for Summary Judgment held on February 27, 2004, the Court asked Defendants to identify the support that the case of Franco v. Yale Univ., 238 F. Supp. 2d 449 (D. Conn., 2002), might lend to the proposition that a claim of good faith and fair dealing required a showing of reliance. The purpose of the Defendants' Second Supplemental Memorandum is to respond to that inquiry. For this reason, the Defendants respectfully request that Court permit the Defendants to file the Second Supplemental Memorandum in Support of Their Motion for Summary Judgment.

ORAL ARGUMENT NOT REQUESTED

Case 3:01-cv-02189-SRU

Document 56

Filed 03/05/2004

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DEFENDANTS - DUPONT FLOORING SYSTEMS, INC. and DUPONT COMMERCIAL FLOORING SYSTEMS, INC. By:

Hugh F. Murray, III - ct11418 Marilyn B. Fagelson - ct17202

Murtha Cullina LLP Whitney Grove Square Two Whitney Avenue P.O. Box 704 New Haven, Connecticut 06503-0704 Telephone: (203) 772-7700 Fax: (203) 772-7723 E-mail: [email protected] [email protected] Their Attorneys

Case 3:01-cv-02189-SRU

Document 56

Filed 03/05/2004

Page 3 of 3

CERTIFICATE OF SERVICE I hereby certify that a copy of the foregoing Defendants' Motion for Permission to File a Second Supplemental Memorandum in Support of Their Motion for Summary Judgment was sent by first class mail, postage prepaid, on March 2, 2004 to Fern H. Paes, Esq. and Michael T. Paes, Esq., Paes & Paes, LLC, 4 Washington Avenue, Sandy Hook, CT 06482.

Marilyn B. Fagelson - ct17202