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

Case 3:01-cv-01913-DJS

Document 121

Filed 01/23/2007

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UNITED STATES DISTRICT COURT DISTRICT OF CONNECTICUT HOWARD JOHN GOMBERT, JR.,: Plaintiff : : v. : : LARRY LYNCH and WILLIAM : KAMINSKI, : Defendants : CIVIL ACTION NO. 3:01CV1913(DJS)

JANUARY 23, 2007

DEFENDANTS' MOTION FOR EXTENSION OF TIME TO FILE SUR-REPLIES REGARDING CROSS MOTIONS FOR SUMMARY JUDGMENT Pursuant to Rule 16(b) of the Federal Rules of Civil Procedure and Local Rule 7(b), the undersigned counsel for defendants LARRY LYNCH and WILLIAM KAMINSKI respectfully moves this Court for an extension of 10 days, from January 29, 2007 to February 8, 2007, to file sur-replies regarding the pending Cross Motions for Summary Judgment. is as follows: 1. On Friday, January 29, 2007, after 9:00 p.m., the The basis for this request

plaintiff filed 5 separate documents regarding the pending Cross Motions for Summary Judgment, including: 1) a 39 page Memorandum in Opposition to the Defendants' Motion for Summary

Case 3:01-cv-01913-DJS

Document 121

Filed 01/23/2007

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Judgment; 2) a 15 page Counterstatement of Facts; 3) a 5 page Affidavit; 4) an 11 page Reply Brief in Support of Plaintiff's Motion for Summary Judgment; and 5) a 15 page Statement of Undisputed Facts. 2. On this date, January 23, 2007, the plaintiff had

hand delivered to the Court, with a copy to counsel, a stack of documents that were manually filed, including plaintiff's exhibits A though V. 3. Because the plaintiff's Exhibits were too large to The stack

electronically file, they were just delivered today.

of documents delivered by the plaintiff today is more than 2 inches thick. 4. The defendants cannot reasonably be expected to

respond to this voluminous filing within the next five business days and require at least 10 extra days to digest this information and prepare a response. 5. On January 23, 2007, the undersigned conferred with

plaintiffs' counsel, Brian Hole, who indicated that he did not take a position regarding this request.

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Case 3:01-cv-01913-DJS

Document 121

Filed 01/23/2007

Page 3 of 4

6.

This is the first requested enlargement of this

deadline by the undersigned; however, the request is prompted primarily by the breadth of the plaintiff's recent filing, not lack of diligence of counsel or the parties. WHEREFORE, the defendants respectfully request this 10 day extension of the deadline to file sur-replies regarding the Cross Motions for Summary Judgment. DEFENDANTS, LARRY LYNCH and WILLIAM KAMINSKI BY /SS/ James N. Tallberg Federal Bar No.: ct17849 Karsten & Dorman, LLC 29 South Main Street West Hartford, CT 06107 Their Attorney Tel. 860-521-4800 Fax. 860-521-7500 [email protected]

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Case 3:01-cv-01913-DJS

Document 121

Filed 01/23/2007

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CERTIFICATION I hereby certify that, on January 23, 2007, a copy of the foregoing was filed electronically and served by mail on anyone unable to accept electronic filing. Notice of this filing will

be sent by e-mail to all parties by operation of the Court's electronic filing system or by mail to anyone unable to accept electronic filing. Court's system. /SS/ James N. Tallberg Parties may access this filing through the

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