Free Motion for Leave to File - District Court of Connecticut - Connecticut

Case 3:01-cv-01977-EBB

Document 88

Filed 03/14/2005

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UNITED STATES DISTRICT COURT DISTRICT OF CONNECTICUT PATRICIA ANN MEDVEY, Plaintiff, V. OXFORD HEALTH PLANS, INC., and METROPOLITAN LIFE INSURANCE COMPANY. Defendants. : : : : : : : : : : CIVIL NO. 3:01-CV1977 (EBB)

MARCH 14, 2005

MOTION FOR LEAVE TO FILE MEMORANDUM OF LAW IN EXCESS OF TEN PAGES Defendant Oxford Health Plans, Inc. respectfully moves the Court for permission to file a Reply Memorandum of Law in Support of Summary Judgment in excess of ten pages. In support of this motion, Defendant represents as follows: 1. Defendant is moving for summary judgment with regard to all four of the

plaintiff's remaining counts. 2. Defendant's memorandum includes several arguments relating to four different

statutes: ERISA (preemption), the Americans with Disabilities Act, the Rehabilitation Act, and the Connecticut Fair Employment Practices Act. The issues concerning these four statutes are complex and require more space than is available than the 10-page limitation of Local Rule 7(d). 3. Defendant believes that, given the nature and extent of the claims by the plaintiff

at issue at this case, the excess pages are required to provide the Court with a thorough, cogent

Case 3:01-cv-01977-EBB

Document 88

Filed 03/14/2005

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analysis of the legal issues and the relevant law. Defendant is hopeful that, if given permission to file a memorandum of law in excess of 10 pages, any and all claims in this action will be disposed of by the court, as a matter of law. WHEREFORE, Defendant respectfully requests that the Court grant its motion to file a memorandum of law in excess of 10 pages. DEFENDANT OXFORD HEALTH PLANS, INC.

By: ________/s/ David J. Burke_______ David A. Kulle (ct00333) [email protected] David J. Burke (ct04373) [email protected] Diane Bucci (ct23763) [email protected] Robinson & Cole LLP 695 East Main Street Stamford, CT 06904 Tel No.: (203) 462-7500 Fax No.: (203) 462-7599

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Case 3:01-cv-01977-EBB

Document 88

Filed 03/14/2005

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CERTIFICATION This is to certify that the foregoing was send via Federal Express to Edmond Clark, Esq., 83 Scotland Avenue, P.O. Box 133, Madison, CT 06443-0133 on this 14th day of March 2005.

________/s/ David J. Burke_____ David J. Burke

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