UNITED STATES DISTRICT COURT
DISTRICT OF CONNECTICUT
JOSE ERNESTO MARTINEZ,
CIVIL ACTION NO.
THE FERGUSON LIBRARY
a division of the City of Stamford, and
the President in his Official Position
FEBRUARY 22, 2008
PLAINTIFF’S THIRD CONSENTED TO MOTION FOR AN EXTENSION OF TIME TO
RESPOND TO DEFENDANTS’ MOTION TO DISMISS
COMES NOW, Plaintiff, by and through undersigned counsel, hereby files its Third
Consented To Motion for an Extension of Time to Respond to Defendants’ Motion to Dismiss and
as grounds for this Motion, state the following:
Plaintiff filed his Complaint on August 8, 2007; and subsequently served Defendants,
on August 24, 2007.
Defendants timely filed their Motion to Dismiss the Complaint on November 29,
On December 11, 2007, the Court granted Plaintiff’s Unopposed Motion for an
Extension of Time to Respond to Defendant’s Motion to Dismiss until January 9, 2008.
On January 2, 2008, the Court granted Plaintiff’s second request for an extension of
time to respond to Defendant’s Motion to Dismiss until February 23, 2008.
However, the parties are still negotiating settlement, finalizing the agreement, have
Martinez v. Ferguson Library et al
exchanged drafts of the terms and expect to have a completed settlement agreement within ten (10)
Accordingly, Plaintiff, with Defendants’ consent, now asks this Court to grant a ten
(10) business day extension of time through and including March 10, 2008, to respond to
Defendants’ Motion to Dismiss.
This motion is filed in good faith and not for the purposes of delay.
Granting this motion will not prejudice any of the parties to this action.
Plaintiff contacted counsel for Defendants regarding this motion and Defendants have
consented to this extension.
WHEREFORE, Plaintiff, Jose Ern