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

Case 3:01-cv-02224-CFD

Document 48

Filed 03/23/2005

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UNITED STATES DISTRICT COURT DISTRICT OF CONNECTICUT

SHERRI PAULEY, ET AL v. TOWN OF ANSONIA, ET AL

: : : : :

NO.: 3:01CV02224 (CFD)

MARCH 22, 2005

MOTION FOR ENLARGEMENT OF TIME

Pursuant to Local Rule 9(b)1(a), the defendants, Town of Ansonia, Sergeant Zalinsky and Kevin Hale, hereby move the Court for an enlargement of time of fourteen (14) days, up to and including April 8, 2005, in which to file a reply to the plaintiff's Objection to Motion for Summary Judgment dated March 8, 2005, and filed on March 1, 2005, which is currently due on March 25, 2005. The additional time is necessary because plaintiff's objection was received in defense counsel's office while the undersigned was on vacation from April 14-18, 2005. The undersigned will be preparing a Reply brief as Attorney Beatrice Jordan, who has been lead counsel on this case and prepared the Motion for Summary Judgment, is on maternity leave. The undersigned has had no prior involvement in this case and so the extension is necessary to review the file and prepare an appropriate response. Also, it appears that the plaintiff is now relying on a violation of her First Amendment right to petition

ORAL ARGUMENT IS NOT REQUESTED

Case 3:01-cv-02224-CFD

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Filed 03/23/2005

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the government as the theory of liability rather than equal protection, as originally pled in the complaint. Thus, additional research will be necessary to prepare the reply brief. The undersigned counsel has contacted counsel for the plaintiff, Attorney Kim Coleman Waisonovitz, and Attorney Waisonovitz has no objection to the granting of this motion. This is the first request for an enlargement of time made by this defendant relative to the defendant's reply brief. WHEREFORE, the undersigned defendants, Town of Ansonia, Sergeant Zalinsky and Kevin Hale, hereby request that their Motion for Enlargement of Time, up to and including April 8, 2005, be granted. DEFENDANTS, TOWN OF ANSONIA, SERGEANT ZALINSKY AND KEVIN HALE

By____/s/ Melinda A. Powell_____ Melinda A. Powell ct17049 Howd & Ludorf, LLC 65 Wethersfield Avenue Hartford, CT 06114 (860) 249-1361 (860) 249-7665 (Fax)

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Case 3:01-cv-02224-CFD

Document 48

Filed 03/23/2005

Page 3 of 3

CERTIFICATION This is to certify that a copy of the foregoing has been sent, handling charges prepaid, via U.S. Mail, to the following counsel of record this 22nd day of March, 2005.

Kim Coleman Waisonovitz, Esquire Law Offices of Norman A. Pattis 649 Amity Road P.O. Box 280 Bethany, CT 06524

_____/s/ Melinda A. Powell______ Melinda A. Powell

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