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

Case 3:01-cv-02402-AWT

Document 191

Filed 05/23/2008

Page 1 of 4

UNITED STATES DISTRICT COURT DISTRICT OF CONNECTICUT PETER D. MAINS and LORI M. MAINS Plaintiffs, v. SEA RAY BOATS, INC., Defendant. : : : : : : : : : CIVIL ACTION NO.: 3:01CV2402 (AWT)

May 23, 2008

PLAINTIFFS' FIRST [UNOPPOSED] MOTION FOR ENLARGEMENT OF TIME TO FILE AN OPPOSITION TO DEFENDANT'S RENEWED MOTION FOR JUDGMENT AS A MATTER OF LAW Pursuant to Rule 6(b) of the Federal Rules of Civil Procedure and Local Rule 7(b), Plaintiffs Lori M. Mains and Peter D. Mains, respectfully submit this motion for an extension of time of fourteen days to file an opposition to Defendant's Renewed Motion for Judgment as a Matter of Law. Counsel for Plaintiffs has inquired of opposing counsel in accordance with Local Rule 7(b)(3), and opposing counsel has agreed to this enlargement of time. Defendant filed a Renewed Motion for Judgment as a Matter of Law on May 2, 2008. Although Defendant has requested oral argument on its motion, Plaintiffs are

unaware of a hearing date having been set. Plaintiffs seek additional time so that counsel might have the opportunity to review the transcript in this case to allow for accurate and appropriate citations to the trial record.

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Case 3:01-cv-02402-AWT

Document 191

Filed 05/23/2008

Page 2 of 4

Plaintiffs have not yet received or had an opportunity to review the trial record despite inquiries as early as May 7, 2008. Notwithstanding the diligence and

cooperation of the court reporters, counsel was unable to coordinate the particulars, payment, and delivery of the transcript in advance of this deadline. This in the first request by Plaintiffs for an extension of time to oppose the subject motion. No party shall suffer prejudice as a result of the requested relief. For all of the reasons set forth herein, Plaintiffs respectfully request that this Court grant the [Proposed] Order on Motion to Enlarge Time filed concurrently herewith. Dated this 23rd day of May, 2008 at Newport Beach, California. Respectfully submitted, PLAINTIFFS, PETER D. MAINS and LORI M. MAINS By _____/s/ Rachel D. Lev______________ Rachel D. Lev, Esq. Connecticut Federal Bar Number PHV02527 HERRICK NIKAS 1201 Dove Street, Suite 560 Newport Beach, California 92660 Telephone: (714) 546-1400 Facsimile: (714) 546-4111 [email protected] Their Attorney

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Case 3:01-cv-02402-AWT

Document 191

Filed 05/23/2008

Page 3 of 4

UNITED STATES DISTRICT COURT DISTRICT OF CONNECTICUT PETER D. MAINS and LORI M. MAINS Plaintiffs, v. SEA RAY BOATS, INC., Defendant. : : : : : : : : : CIVIL ACTION NO.: 3:01CV2402 (AWT)

May 23, 2008

[PROPOSED] ORDER ON MOTION TO ENLARGE TIME Having reviewed the unopposed Motion for Enlargement of Time to File an Opposition to Defendant's Renewed Motion for Judgment as Matter of Law, and pursuant to Rule 6(b) of the Federal Rules of Civil Procedure and Local Rule 7, the Motion is HEREBY GRANTED. Plaintiffs shall file their Opposition to Defendant's Renewed Motion for Judgment as a Matter of Law on or before June 6, 2008. SO ORDERED, this _____ day of _______, 2008, at Hartford, Connecticut.

________________________________________ The Honorable Judge Alvin W. Thompson United States District Court, District of Connecticut

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Case 3:01-cv-02402-AWT

Document 191

Filed 05/23/2008

Page 4 of 4

CERTIFICATION I hereby certify that on this date a copy of the foregoing Plaintiffs' First [Unopposed] Motion For Enlargement of Time to File an Opposition to Defendant's Renewed Motion for Judgment as a Matter of Law and [Proposed] Order On Motion to Enlarge Time were filed electronically and served by mail on anyone unable to accept electronic filing. Notice of this filing will be sent by e-mail to all parties by operation of the Court's electronic filing system or by mail to anyone unable to accept electronic filing as indicated on the Notice of Electronic Filing. Parties may access this filing through the Court's CM/ECF System. ________/s/ Rachel D. Lev___________ Rachel D. Lev Connecticut Federal Bar Number PHV02527

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