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

Case 3:01-cv-02361-MRK

Document 126

Filed 06/28/2005

Page 1 of 3

UNITED STATES DISTRICT COURT FOR THE DISTRICT OF CONNECTICUT JANICE C. AMARA, individually and on behalf of others similarly situated, Plaintiff, vs. CIGNA CORP. AND CIGNA PENSION PLAN, Defendants. : : : : : : : : : : : CIVIL ACTION NO. 3:01-CV-2361 (MRK)

JUNE 27, 2005

PLAINTIFF'S UNOPPOSED MOTION FOR THREE DAY EXTENSION OF TIME TO FILE REPLY MEMORANDUM IN SUPPORT OF HER MAY 6, 2005 MOTION IN LIMINE Plaintiff, Janice Amara ("Amara") hereby respectfully requests a three-day extension of time through and including July 1, 2005 in which to respond to defendants' objection to plaintiff's motion in limine dated May 6, 2005 in the above-captioned matter. In support hereof, Amara respectfully represents as follows: 1. Plaintiff's response is currently due on June 28, 2005; 2. Both of Amara's counsel have been occupied with briefs and discovery matters to meet preexisting deadlines in other courts, and the subject matter at issue in the motion is complicated;

Case 3:01-cv-02361-MRK

Document 126

Filed 06/28/2005

Page 2 of 3

3.

Because of their other commitments, counsel have been unable to

complete the research and briefing necessary to respond to defendants' objection; 4. This is Amara's first request to extend this deadline; 5. Defense counsel consents to the granting of this motion. WHEREFORE, Amara respectfully moves for a three-day extension of time through and including July 1, 2005 in which to respond to defendants' objection to plaintiff's May 6, 2005 motion in limine.

THE PLAINTIFF By______________________ Thomas G. Moukawsher Fed. Bar. No.: ct08940 Moukawsher & Walsh, LLC 21 Oak Street, Suite 209 Hartford, CT 06106 (860) 278-7003 Stephen R. Bruce (Proc Hac Vice) Suite 210 805 15th St., NW Washington, DC 20005 (202) 371-8013

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Case 3:01-cv-02361-MRK

Document 126

Filed 06/28/2005

Page 3 of 3

CERTIFICATION I hereby certify that a copy of the foregoing has been mailed on this date to the defendant at: Christopher A. Parlo Morgan, Lewis & Bockius 101 Park Avenue New York, NY 10178 Jeremy P. Blumenfeld Joseph J. Costello Morgan, Lewis & Bockius 1701 Market Street Philadelphia, PA 19103-2921 Dated this 27th day of June, 2005. _______________________ Thomas G. Moukawsher

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