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

Case 3:01-cv-02129-AVC

Document 70

Filed 07/20/2004

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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 16, 2004 : : : CONSOLIDATED CASES : : 301CV2129 (AVC)

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 August 9, 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 16, 2004. The facts are complex and hotly

They have not responded and so there is no way to tell Defendants' position on the extension.

Case 3:01-cv-02129-AVC

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Filed 07/20/2004

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3. reviewed. 4.

There are an enormous amount of documents to be

There are over 6,000 pages of deposition transcripts to

be reviewed. 5. Counsel for the plaintiffs has an extremely busy

calendar for the next twenty three days. 6. This is the third extension sought to prepare the

Pretrial Memo. WHEREFORE, for all of the accompanying reasons, Plaintiffs respectfully moves for an order granting until August 9, 2004 to file the Pretrial Memo. THE PLAINTIFFS DEBRA COSENTINO, ET AL

By:_______________________ WILLIAM B. BARNES, ESQ. (CT00268) Rosenstein & Barnes P.O. Box 687 1100 Kings Hwy. East, Fairfield, CT 06824 (203) 367-7922 E-Mail [email protected]

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Case 3:01-cv-02129-AVC

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CERTIFICATION A copy of the foregoing was faxed and mailed to the following persons on July 16, 2004: Lawrence Peikes, Esq. Wiggin & Dana, LLP 400 Atlantic St., P.O. Box 110325 Stamford, CT 06911-0325 ______________________________ WILLIAM B. BARNES, ESQ.

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Case 3:01-cv-02129-AVC

Document 70

Filed 07/20/2004

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