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

Case 3:01-cv-01979-WWE

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Filed 05/27/2004

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UNITED STATES DISTRICT COURT DISTRICT OF CONNECTICUT

KARL HOGFELDT

: : v. : : OLD SAYBROOK POLICE DEPARTMENT : SERGEANT DONALD HULL; PATROLMAN : DAVID PERRROTTI; PATROLMAN CHRIS : DEMARCO; PATROLMAN JAY RANKIN; : EACH INDIVIDUALLY AND AS POLICE : OFFICERS AND MEMBERS OF THE OLD : SAYBROOK POLICE DEPARTMENT; AND : THE TOWN OF OLD SAYBROOK :

NO.: 3:01CV1979 (WWE)

MAY 26, 2004

MOTION FOR ENLARGEMENT OF TIME IN WHICH TO FILE REPLY BRIEF The defendants, Town of Old Saybrook Police Department, Sergeant Donald Hull, Patrolman David Perrrotti, Patrolman Chris DeMarco, Patrolman Jay Rankin and the Town of Old Saybrook, hereby move the Court for an enlargement of time up to and including July 15, 2004, in which to file a reply brief. In support of this motion, the defendants offer as follows: 1. The plaintiff recently filed his objection to the defendants' motion for

summary judgment dated May 18, 2004. The plaintiff's memorandum of law in opposition relies on affidavits from expert witnesses. 2. In order to file a complete and accurate reply, the defendants need to

depose the plaintiff's experts.

Case 3:01-cv-01979-WWE

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3.

Therefore, any reply memorandum should be filed following the

deposition of said experts. The undersigned counsel has been unable to contact counsel for the plaintiff, Attorney A. Paul Spinella, to ascertain his position as to the granting of this motion. This is the first request for an enlargement of time made by this defendant relative to the plaintiff's opposition memorandum to defendants motion for summary judgment. WHEREFORE, the undersigned defendants pray that they have until July 15, 2004 in which to file a reply memorandum. DEFENDANTS, OLD SAYBROOK POLICE DEPARTMENT, SERGEANT DONALD HULL, PATROLMAN DAVID PERRROTTI, PATROLMAN CHRIS DEMARCO, PATROLMAN JAY RANKIN AND THE TOWN OF OLD SAYBROOK

By/s/John J. Radshaw, III John J. Radshaw, III ct19882 Howd & Ludorf 65 Wethersfield Avenue Hartford, CT 06114 (860) 249-1361 (860) 249-7665 E-mail: [email protected]

Case 3:01-cv-01979-WWE

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Case 3:01-cv-01979-WWE

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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 26th day of May, 2004.

Bruce E. Newman, Esquire Newman, Creed & Associates 99 North Street, Route 6 P.O. Box 575 Bristol, CT 06011 A. Paul Spinella, Esquire Spinella & Associates One Lewis Street Hartford, CT 06103 /s/John J. Radshaw, III John J. Radshaw, III