Soto et al v. Bushmaster Firearms International, LLC et al

MOTION for Leave to File Excess Pages

D. Conn.March 24, 2015

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF CONNECTICUT DONNA L. SOTO, ADMINISTRATRIX OF ) THE ESTATE OF VICTORIA L. SOTO, et al. ) ) Plaintiffs, ) Civil Action No. 3:15-cv-68 (RNC) ) VS. ) ) BUSHMASTER FIREARMS ) INTERNATIONAL, LLC a/k/a/ FREEDOM ) GROUP, INC. a/k/a/ REMINGTON OUTDOOR ) March 24, 2015 GROUP, INC., et al. ) ) Defendants. ) PLAINTIFFS’ MOTION FOR LEAVE TO FILE REPLY BRIEF IN EXCESS OF TEN PAGES Pursuant to Local Rule 7(d), plaintiffs’ Reply to defendants’ Memorandum of Law in Opposition to Plaintiffs’ Motion to Remand may not exceed ten pages. Plaintiffs respectfully request leave of the Court to exceed the ten page limit by up to five additional pages. In support of this Motion, plaintiffs represent as follows: 1. This case was removed to this Court on January 14, 2015. 2. Plaintiffs filed a Motion to Remand on February 13, 2015 (Dkt. No. 27). 3. Defendants Remington Arms Company, LLC, and Remington Outdoor Company, Inc. filed a Memorandum in Opposition to the Motion to Remand on March 6, 2015 (Dkt. No. 34). 4. On March 10, 2015, plaintiffs were granted a seven day extension in which to respond to defendants’ Opposition (Dkt. No. 36). 5. Plaintiffs’ Reply is due March 27, 2015. 1 Case 3:15-cv-00068-RNC Document 37 Filed 03/24/15 Page 1 of 3 6. The issues raised by defendants’ removal and plaintiffs’ subsequent Motion to Remand are complex and critical to fully address as the Court’s subject matter jurisdiction is in issue. 7. Plaintiffs are making a concerted effort to confine their Reply to ten pages in accordance with Local Rule 7(d), but believe that up to five additional pages may be necessary to adequately address the relevant issues. 8. Plaintiffs’ counsel has contacted counsel for each of the defendants, and they have no objection to the granting of this Motion. For the above reasons, plaintiffs respectfully request that the Court grant this Motion and permit plaintiffs to file a Reply of up to 15 pages in length. DATED: March 24, 2015 Respectfully submitted, By /s/ Alinor C. Sterling (CT17207) ALINOR C. STERLING, CT17207 JOSHUA D. KOSKOFF, CT15619 KOSKOFF KOSKOFF & BIEDER 350 FAIRFIELD AVENUE BRIDGEPORT, CT 06604 asterling@koskoff.com jkoskoff@koskoff.com Telephone: (203) 336-4421 Fax: (203) 368-3244 ATTORNEYS FOR PLAINTIFFS 2 Case 3:15-cv-00068-RNC Document 37 Filed 03/24/15 Page 2 of 3 CERTIFCIATE OF SERVICE I hereby certify that on March 24, 2015, a copy of the foregoing Motion 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 as indicated on the Notice of Electronic Filing. Parties may access this filing under the court’s CM/ECF System. /s/ Alinor C. Sterling (CT17207) ALINOR C. STERLING, CT17207 JOSHUA D. KOSKOFF, CT15619 3 Case 3:15-cv-00068-RNC Document 37 Filed 03/24/15 Page 3 of 3