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

Case 3:01-cv-01918-SRU

Document 63

Filed 05/06/2004

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UNITED STATES DISTRICT COURT DISTRICT OF CONNECTICUT SANDRA SODERLUND PLAINTIFF VS. JANICE MERRIGAN, ET AL DEFENDANTS : : : : : : : CIVIL ACTION

CASE NO. 3:01CV1918 (SRU)

MAY 5, 2004

DEFENDANTS' MOTION FOR AN EXTENSIONOF TIME TO FILE A SUMMARY JUDGMENT MOTION

The Defendants, Janice Merrigan, James Mroczka and the City of Meriden hereby respectfully move for an additional 30 days from May 15, 2004, until June 15, 2004 to file their motion for summary judgment in the above captioned matter. In accordance with L.Civ.R. 9(b), and in support of this motion, the Defendants represent as follows: 1. The deposition of the Plaintiff, Ms. Soderlund was originally noticed for Friday March 5, 2004. It was moved to March 25, 2004 because Ms. Soderlund was out of town on the original date. It was reasonably

believed that this continuance would not interfere with the filing deadlines established in this matter.

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Case 3:01-cv-01918-SRU

Document 63

Filed 05/06/2004

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2.

However, the transcript of Ms. Soderlund's deposition did not arrive in the undersigned's office until yesterday, May 4, 2004.

3.

Inasmuch as the Plaintiff's deposition testimony plays a large part of this action, and will be relied upon in the summary judgment motion and memorandum, the arrival of the transcript only yesterday does not give the undersigned adequate time to prepare a motion for summary judgment and the accompanying documents.

4.

The undersigned inquired of opposing counsel's office with regard to this motion. While the opposing counsel is on trial and unavailable, his staff represented that there would be no objection to this request. Past requests for extensions of time from either counsel in this matter have never been objected to.

5.

This is the first such motion for extension of time with respect to the Motion for Summary Judgment.

WHEREFORE, the Defendants respectfully request that this Motion for Extension of Time to file their summary judgment motion and accompanying documents be granted until June 15, 2004.

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Case 3:01-cv-01918-SRU

Document 63

Filed 05/06/2004

Page 3 of 3

THE DEFENDANTS JANICE MERRIGAN JAMES MROCZKA CITY OF MERIDEN

By:

/S/ Deborah L. Moore Their Attorney City of Meriden Legal Department City Hall 142 East Main Street Meriden, CT 06450 Telephone: (203) 630-4045 Facsimile: (203 630-7907 Email: [email protected] Juris No. CT17792

CERTIFICATION This is to certify that on the 5th day of May, 2004, a copy of the foregoing was mailed, postage prepaid, to the following: Bruce Chaplin, Esq., 208 Main Street, Durham, CT 06422

/S/ Deborah L. Moore City of Meriden Legal Department City Hall 142 East Main Street Meriden, CT 06450 Telephone: (203) 630-4045 Facsimile: (203 630-7907 Email: [email protected] Juris No. CT17792

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