Shorter v. Hartford Financial, et al

MOTION for Extension of Time until 7/23/04 to File Response as to 73 MOTION to Strike 65 Affidavit

D. Conn.July 14, 2004

UNITED STATES DISTRICT COURT DISTRICT OF CONNECTICUT FERRON SHORTER JR., : : Plaintiff, : CASE NO.: 3:03CV0149(WIG) : v. : : HARTFORD FINANCIAL SERVICES GROUP, : INC., MARYANNE RHODES, : : Defendants. : JULY 9, 2004 PLAINTIFF’S MOTION FOR EXTENSION OF TIME Plaintiff Ferron Shorter Jr., by and through his undersigned counsel, and pursuant to Local Rule 7(b)(1) of this District, moves for an extension of fourteen (14) days, until July 23, 2004, to file an Objection to Defendant MaryAnne Rhodes’ Motion to Strike Plaintiff’s Affidavit supporting his objection to Defendant Rhodes’ Motion for Summary Judgment. 1. The extended time for Plaintiff to respond to Defendant Rhodes’ Motion to Strike expires on July 9, 2004. 2. The instant motion for extension is Plaintiff’s third such motion regarding Defendant Rhodes’ Motion to Strike. 3. Plaintiff’s first motion for an extension of time was for a period of thirty (30) days. 4. Plaintiff’s second motion for an extension of time was for a period of nine (9) days. 5. Plaintiff’s counsel has inquired of opposing counsel and represents that counsel for Defendant Rhodes stated no objection and counsel for Defendant Hartford Financial Services Group objects to any extension of time to object. Case 3:03-cv-00149-WIG Document 78 Filed 07/14/2004 Page 1 of 3 2 6. As good cause for this second motion, the undersigned represents that during the past two weeks matters which commenced during the time period previous to the second continuance, and described in that request, have continued to consume unanticipated resources and time. For the foregoing reasons, Plaintiff respectfully requests an extension of fourteen (14) days until July 23, 2004. PLAINTIFF FERRON SHORTER JR. BY: ________________________________ Rachel M. Baird (Fed. Bar No. 12131) Law Office of Rachel M. Baird 379 Prospect Street Torrington CT 06790-5239 Tel: (860) 626-9991 Fax: (860) 626-9992 Case 3:03-cv-00149-WIG Document 78 Filed 07/14/2004 Page 2 of 3 3 CERTIFICATION I HEREBY CERTIFY THAT the foregoing Plaintiff’s Motion for Extension of Time was mailed, first-class, postage-paid, on July 9, 2004, to: David L. Metzger, Esq. Metzger & Associates 25 Capitol Ave Hartford CT 06106 Margaret J. Strange, Esq. Jackson Lewis LLP 55 Farmington Ave Ste 1200 Hartford CT 06105 __________________________ Rachel M. Baird Case 3:03-cv-00149-WIG Document 78 Filed 07/14/2004 Page 3 of 3