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

Case 3:01-cv-02037-MRK

Document 29

Filed 01/14/2004

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UNITED STATES DISTRICT COURT DISTRICT OF CONNECTICUT

-----------------------------------------------------------X Kendra HEWITT, Darlene WHALEY and Ethel L. Wright Individually and as Class Representative, Plaintiff,

Civil Action No. 3:01 CV 2037 (MRK) Motion - for Extension of Time to File Motion for Class Certification

v. THE METROPOLITAN DISTRICT COMMISSION, Defendant. -----------------------------------------------------------X Plaintiffs hereby move the Court for a seven (7) day extension of time to file their Motion for Class Certification and accompanying documents. The Plaintiffs also ask, in the interest of fairness, that the Defendant be likewise granted a seven (7) day extension to respond. The Court's Scheduling Order presently provides a due date of January 15, 2004 for the Plaintiffs' motion and February 5, 2004 for Defendant's response. In the interests of maintaining the timetable set forth in the Scheduling Order as best as possible, the Plaintiffs

Case 3:01-cv-02037-MRK

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Filed 01/14/2004

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will submit their reply to the Defendant's response by February 19, 2004, not asking for an extension to that date. The undersigned represents that Attorney Anthony Palermino, counsel for the Defendant, was contacted and has no objection to this seven (7) day extension, so long as the Defendants are provided the same courtesy. The Plaintiffs recognize the necessity for this case to progress in a timely fashion, but beg the Court's deference in these rather extraordinary circumstances. Attorney Robert W. Heagney is the lead counsel for the Plaintiffs, but, due to recent political developments involving the Governor of Connecticut, he has been unable to devote his full attention to the Plaintiffs' forthcoming motion. These circumstances were not foreseeable at the time of the scheduling conference, but the Plaintiffs will endeavor to provide a reasoned argument for class certification within this seven (7) day extension that will adequately protect the interests of the putative class members.

Case 3:01-cv-02037-MRK

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Filed 01/14/2004

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Respectfully submitted, THE PLAINTIFFS

By: ____________________________ Stuart E. Brown (ct24659) Hassett & George, P.C. 555 Franklin Avenue Hartford, CT 06114 (860) 296-2111 Fax: (860) 296-8494

CERTIFICATION I hereby certify that a copy of the foregoing has been mailed this ___ day of January, 2004 to the following counsel of record: Anthony J. Palermino, Esq. Law Offices of Anthony J. Palermino 945 Wethersfield Avenue Hartford, CT 06114 __________________________________ Stuart E. Brown