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

Case 3:01-cv-01979-WWE

Document 72

Filed 05/11/2005

Page 1 of 2

UNITED STATES DISTRICT COURT DISTRICT OF CONNECTICUT KARL HOGFELDT Plaintiff vs. OLD SAYBROOK POLICE DEPARTMENT SERGEANT DONALD HULL; PATROLMAN DAVID PERROTTI; PATROLMAN CHRIS DEMARCO; PATROLMAN J RANKIN; AY EACH INDIVIDUALLY AND AS POLICE OFFICERS AND MEMBERS OF THE OLD SAYBROOK POLICE DEPARTMENT; AND THE TOWN OF OLD SAYBROOK OF OLD SAYBROOK Defendants : : : : : : : : : : : : : : : CIVIL ACTION NO. 3:01 CV 1979 (WWE)

MAY 9, 2005

MOTION TO ENLARGE TIME RE: J OINT TRIAL MEMORANDUM The Plaintiff in the above-referenced matter hereby requests an enlargement of time to file a J oint Trial Memorandum of ten (10) days. In support of said request the Plaintiff hereby represents: 1. Additional time is required because of the demands of the undersigned present trial calendar which has prevented him from completing this matter in conjunction with defense counsel; 2. The Plaintiff has begun work on this matter which has been substantially completed in draft form; 3. 4. This is the first request for additional time; Defense counsel has no objection to this request.

Case 3:01-cv-01979-WWE

Document 72

Filed 05/11/2005

Page 2 of 2

ACCORDINGLY, the Plaintiff hereby requests an extension of time of ten (10) days to May 19, 2005 for filing said Motion. PLAINTIFF,

BY_______________________________ A. Paul Spinella, Esq. Spinella & Associates One Lewis Street Hartford, CT 06103 Telephone: 860 728-4900 Federal Bar #: ct00078 Email: [email protected]

CERTIFICATION THIS IS TO CERTIFY that a copy of the foregoing has been mailed postage pre-paid on this date to: Daniel C. DeMerchant, Esq. Thomas R. Gerarde, Esq. J ohn J Radshaw, III . Howd & Ludorf 65 Wethersfield Avenue Hartford, CT 06114-1190 Bruce E. Newman, Esq. Law Offices of Bruce E. Newman, LLC One High Street P.O. Box 927 Deep River, CT 06417

__________________________ A. Paul Spinella, Esq.