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

Case 3:01-cv-01866-RNC

Document 59

Filed 03/02/2005

Page 1 of 3

UNITED STATES DISTRICT COURT DISTRICT OF CONNECTICUT ESTATE OF ANN PARDEE, BY CHERYL GARIEPY, ADMINISTRATRIX, Plaintiff, v. UNITED STATES OF AMERICA, Defendant. : : : : : : : : : : : : CIVIL NO. 3:01CV1866 (RNC)

FEBRUARY 28, 2005

DEFENDANT UNITED STATES OF AMERICA'S MOTION TO REOPEN, NUNC PRO TUNC, AND TO EXTEND TIME TO FILE CLOSING PAPERS The Defendant, United States of America, hereby respectfully moves this Court, nunc pro tunc, to reopen this case for purposes of extending the time within which the parties may submit their closing papers. Specifically, the government seeks until March 28, 2005 to file such papers. By way of background, on or about January 21, 2005 the Defendant reported this case as settled. Shortly thereafter, this Court issued an Order closing the file without prejudice to reopening by February 21, 2005, and indicating that the parties should file any closing papers by February 1, 2005. The government now seeks to reopen this Judgment of Dismissal on the grounds that additional time is needed for the settlement proceeds to be paid out by the Judgment Fund. The settlement process took some time in this case because the settlement first had to be formally approved by the Department of Justice, which has occurred. The settlement proceeds must now be paid by the Judgment Fund, which request is pending, and is expected within the time sought in this motion.

Case 3:01-cv-01866-RNC

Document 59

Filed 03/02/2005

Page 2 of 3

This is the first request to extend this deadline. Counsel for the Plaintiff could not be reached to ascertain his position as to the extension sought. Respectfully submitted, KEVIN J. O'CONNOR UNITED STATES ATTORNEY LAUREN M. NASH, ct01705 ASSISTANT U.S. ATTORNEY UNITED STATES ATTORNEY'S OFFICE 157 CHURCH STREET, P.O. BOX 1824 NEW HAVEN, CT 06510 Telephone: (203) 821-3700 Facsimile: (203) 773-5373 E-mail: [email protected]

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Case 3:01-cv-01866-RNC

Document 59

Filed 03/02/2005

Page 3 of 3

CERTIFICATE OF SERVICE This is to certify that a copy of the within and foregoing was mailed, postage prepaid, on this 28th day of February, 2005, to: Robert I. Reardon, Jr., Esq. The Reardon Law Firm, P.C. 160 Hempstead Street, P.O. Drawer 1430 New London, Ct 06320

LAUREN M. NASH ASSISTANT U.S. ATTORNEY

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