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

Case 3:01-cv-02298-SRU

Document 92

Filed 03/01/2006

Page 1 of 4

UNITED STATES DISTRICT COURT DISTRICT OF CONNECTICUT JANE DOE, JR., et al. Plaintiffs, vs. CITY OF WATERBURY, et al. Defendants. SUSAN ROE, JR., et al. Plaintiffs, vs. CITY OF WATERBURY, et al. Defendants. : : : : : Master Consolidated (Lead Case) Civil 3:01cv2298 (SRU)

: : : : : :

NO.: 3:03cv00571(SRU) (Member Case)

FEBRUARY 27, 2006

MOTION FOR EXTENSION OF TIME As reflected in the undersigned's Motion for Extension dated January 17, 2006, the undersigned is currently working on a Response/Reply with regard to the lead case, and expects to be filing one in the member case as well. The undersigned respectfully requests that the deadline to file his Response/Reply in the lead case be the same as the deadline he is assigned in the member case. Currently, the undersigned has been allowed until February 27, 2006 to file his response in the lead case. However, on February 22, 2006, Erskine McIntosh, Esquire, plaintiff's attorney in the member case, requested additional time to file his Objection and Motion for Summary Judgment. In the interest of judicial economy and to prevent any confusion that might be presented by two separate filings, the undersigned, rather than asking for a date certain, is requesting that he be allowed ten days after the filing of Attorney Erskine McIntosh's Objection and/or Motion for Summary Judgment, to file his Response/Reply in the lead case.

NOBLE, SPECTOR, YOUNG & O'CONNOR, P.C. · ATTORNEYS AT LAW ONE CONGRESS STREET · HARTFORD CT 06114-1067 · JURIS NO. 409138 · TEL: (860) 525-9975 · FAX: (860) 525-9985

Case 3:01-cv-02298-SRU

Document 92

Filed 03/01/2006

Page 2 of 4

This is the second such request for an extension filed by the undersigned with regard to filing a Response/Reply in the lead case. Pursuant to Local Rule 9(b)(2), the office of the undersigned contacted the office of Attorney Michael S. Hillis, who stated that he has no objection to this motion. WHEREFORE, the undersigned respectfully requests that the court assign a deadline for his Response/Reply in both the lead and member cases of ten days after the filing of Erskine McIntosh's Objection and Motion for Summary Judgment. DEFENDANT: City of Waterbury

BY: ______________________________ Elliot B. Spector Federal Bar #ct05278 Noble, Spector, Young & O'Connor One Congress Street Hartford, CT 06114 Phone: 860-525-9975 Fax: 860-525-9985 [email protected]

NOBLE, SPECTOR, YOUNG & O'CONNOR, P.C. · ATTORNEYS AT LAW ONE CONGRESS STREET · HARTFORD CT 06114-1067 · JURIS NO. 409138 · TEL: (860) 525-9975 · FAX: (860) 525-9985

Case 3:01-cv-02298-SRU

Document 92

Filed 03/01/2006

Page 3 of 4

CERTIFICATION This is to certify that a copy of the foregoing has been mailed, postage prepaid, to the following counsel of record this 27th day of February, 2006.

For the Plaintiffs, Jane Doe, Sr. & Jane Doe, Jr., ppa Erskine D. McIntosh, Esquire Law Offices of Erskine D. McIntosh P.O. Box 185789 Hamden, CT 06518 Michael Stanton Hillis, Esquire Dombroski, Knapsack & Hillis 129 Whitney Avenue New Haven, CT 06510 For the Defendant, Philip Giordano Andrew B. Bowman, Esquire Law Offices of Andrew Bowman 1804 Post Road East Westport, CT 06880 Michael W. Mackniak, Esquire 87 Meadow Street Naugatuck, CT 06770 Gerald Lewis Harmon, Esquire 290 Pratt Street Meriden, CT 06450 Allison Louise Jacobs, Esquire 84 Sherman Avenue Hamden, CT 06518 Lynn Jenkins, Esquire 129 York Street, Apt. 8-L New Haven, CT 06511

________________________________ Elliot B. Spector

NOBLE, SPECTOR, YOUNG & O'CONNOR, P.C. · ATTORNEYS AT LAW ONE CONGRESS STREET · HARTFORD CT 06114-1067 · JURIS NO. 409138 · TEL: (860) 525-9975 · FAX: (860) 525-9985

Case 3:01-cv-02298-SRU

Document 92

Filed 03/01/2006

Page 4 of 4

Clerk's Office United States District Court 915 Lafayette Boulevard Bridgeport, CT 06604

NOBLE, SPECTOR, YOUNG & O'CONNOR, P.C. · ATTORNEYS AT LAW ONE CONGRESS STREET · HARTFORD CT 06114-1067 · JURIS NO. 409138 · TEL: (860) 525-9975 · FAX: (860) 525-9985