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

Case 3:01-cv-02298-SRU

Document 90

Filed 01/20/2006

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)

JANUARY 17, 2006

MOTION FOR EXTENSION OF TIME On or about December 28, 2005, the plaintiff's attorney, Michael S. Hillis, Esquire, in the 3:01CV2298 (SRU) (lead case), filed his "Memorandum of Law in Further Support of Plaintiff's Motion for Summary Judgment AND in Opposition to Defendant, City of Waterbury's Motion for Summary Judgment." On or about January 11, 2006, the plaintiff's attorney, Erskine D. McIntosh, Esquire, in 3:03CV00571 (SRU) (member case) moved for an extension of time to file his Response/Reply, to which the undersigned did not object. He has requested until February 16, 2006. If his Response/Reply is filed on that date, the undersigned would have until February 27, 2006 within which to file a Response/Reply. 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.

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 90

Filed 01/20/2006

Page 2 of 4

The undersigned respectfully requests that he be allowed until February 27, 2006 to file his Response/Reply in the lead case in the interest of judicial economy and to prevent any confusion that might be presented by two separate filings. This is the first 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 until February 27, 2006. 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 90

Filed 01/20/2006

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 17th day of January, 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 90

Filed 01/20/2006

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