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

Case 3:01-cv-02129-AVC

Document 73

Filed 08/02/2004

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UNITED STATES DISTRICT COURT DISTRICT OF CONNECTICUT DEBRA COSENTINO, ET AL, Plaintiffs, v. PITNEY BOWES, INC. and IMAGISTICS INTERNATIONAL, INC., Defendants. : July 29, 2004 : : : CONSOLIDATED CASES : : 301CV2129 (AVC)

CONSENT MOTION FOR EXTENSION OF TIME Plaintiffs move pursuant to Local Civ. R. 9(b) (2) to extend the time to file a Pretrial Memo until September 29, 2004, and represent: 1. These consolidated five plaintiff, two defendant Title

VII actions are based upon several theories of discrimination and retaliation and arise out of many different incidents, involving different Plaintiffs and employees of Defendants, which took place over several years. contested. 2. Counsel for Defendants was contacted on July 29, 2004. The facts are complex and hotly

They consent without abandoning their pending motion.

Case 3:01-cv-02129-AVC

Document 73

Filed 08/02/2004

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3. 4. reviewed. 5.

Counsel for the Plaintiffs has been hospitalized. There are an enormous amount of documents to be

There are over 6,000 pages of deposition transcripts to

be reviewed. 6. This is the fourth extension sought to prepare the

Pretrial Memo. WHEREFORE, for all of the accompanying reasons, Plaintiffs respectfully moves for an order granting until September 29, 2004 to file the Pretrial Memo. THE PLAINTIFFS DEBRA COSENTINO, ET AL

By:_______________________ SHEILA K. ROSENSTEIN, ESQ. (CT07091) Rosenstein & Barnes P.O. Box 687 1100 Kings Hwy. East, Fairfield, CT 06824 (203) 367-7922 EMail [email protected]

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Case 3:01-cv-02129-AVC

Document 73

Filed 08/02/2004

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CERTIFICATION A copy of the foregoing was faxed and mailed to the following persons on July 29, 2004: Lawrence Peikes, Esq. Wiggin & Dana, LLP 400 Atlantic St., P.O. Box 110325 Stamford, CT 06911-0325 ______________________________ SHEILA K. ROSENSTEIN, ESQ

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