Tatum v. Oberg et alMOTION for Extension of Time until 10-23-09 Draft ObjectionD. Conn.October 20, 2009 DEFILIPPO & RUSSO LLC ATTORNEYS AT LAW 4 RESEARCH DRIVE, SUITE 402 SHELTON, CONNECTICUT 06484 203-242-3011 JURIS NO. 425978 UNITED STATES DISTRICT COURT DISTRICT OF CONNECTICUT ____________________________________ ) GARY TATUM, Individually, ) Plaintiff, ) ) C.A. No. 3:08-CV-01251-JCH v. ) ) MARY CHRISTINA OBERG and ) FORD, OBERG, MANIOIN and ) HOUCK, PC ) Defendants. ) ___________________________________ ) OCTOBER 20, 2009 MOTION FOR EXTENSION OF TIME TO RESPOND TO MOTION FOR SUMMARY JUDGMENT Pursuant to Local Rule 7(b)(2), the undersigned, on behalf of Plaintiff Gary Tatum, hereby moves this Court to grant him an extension of time of two weeks, up to and including October 23, 2009, within which to file an objection to the pending Motion for Summary Judgment. In support of the foregoing, Plaintiff submits that additional time is necessary to afford counsel with sufficient time to prepare a response and, despite diligent efforts, the undersigned counsel cannot meet the current deadline. This is the first time that Plaintiff Gary Tatum has moved for an extension of time within which to respond to the pending Motion for Summary Judgment. Counsel for Mary Christina Oberg and Ford Oberg Manion and Houck PC consent to this request. 2 DEFILIPPO & RUSSO LLC ATTORNEYS AT LAW 4 RESEARCH DRIVE, SUITE 402 SHELTON, CONNECTICUT 06484 203-242-3011 JURIS NO. 425978 Dated at Shelton, Connecticut this 20th day of October, 2009. PLAINTIFF GARY TATUM BY /s/ Tracey Lane Russo Tracey Lane Russo, Esq. Fed. Bar. No. CT19865 Email: trusso@defilipporusso.com CERTIFICATION I hereby certify that on October 20, 2009, 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 as indicated on the Notice of Electronic Filing. Parties may access this filing through the Court s CM/ECF System. /s/ Tracey Lane Russo Tracey Lane Russo, Esq.
