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

Case 3:01-cv-02183-AVC

Document 52

Filed 05/11/2005

Page 1 of 3

UNITED STATES DISTRICT COURT DISTRICT OF CONNECTICUT EDWARD BOGANSKI VS. CITY OF MERIDEN BOARD OF EDUCATION, ET AL. : : : : NO. 3:01CV2183(AVC)

MAY 11, 2005

PLAINTIFF'S MOTION FOR EXTENSION OF TIME TO RESPOND TO DEFENDANTS' MOTION FOR SUMMARY JUDGMENT

The plaintiff, EDWARD BOGANSKI, respectfully requests an extension of time of twenty (20) days, up to and including June 8, 2005, to file a response to defendant's Motion for Summary Judgment. The request is made for the following reasons: 1. Plaintiff's counsel has several motions similar to this one pending in federal court. 2. Plaintiff's counsel also must file a closing brief shortly in an employment arbitration which concluded May 3. 3. This is the first request for an extension of time requested by plaintiff's counsel. 4. Plaintiff contacted counsel for the defendant who has no objection to the requested extension of time.

Case 3:01-cv-02183-AVC

Document 52

Filed 05/11/2005

Page 2 of 3

For the reasons set forth above, plaintiff's counsel requests that the motion be granted.

THE PLAINTIFF

BY:_________/s/___________ KATRENA ENGSTROM (ct09444) 51 Elm Street New Haven, CT 06510 203/562-9931 FAX: 203/776-9494 E-Mail: [email protected] His Attorney

CERTIFICATION OF SERVICE This is to certify that a copy of the foregoing was sent via first class mail, postage prepaid, on the date set forth above, to the following counsel of record: Attorney Alexandria L. Voccio Howd & Ludorf 65 Wethersfield Avenue Hartford, CT 06114-1190 Attorney Deborah L. Moore Corporation Counsel's Office 142 East Main Street, Room 240 Meriden, CT 06450

2

Case 3:01-cv-02183-AVC

Document 52

Filed 05/11/2005

Page 3 of 3

Gary Phelan, Esq. Klebanoff & Phelan, P.C. 433 South Main Street, Suite 117 West Hartford, CT 06110 /s/ Katrena Engstrom

3