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
DECEMBER 28, 2007
PLAINTIFF’S 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 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.
However, the parties are currently engaged in settlement negotiations and anticipate
resolving this matter shortly.
Accordingly, Plaintiff, with Defendants’ consent, now asks this Court to grant a forty
Martinez v. Ferguson Library et al
five (45) day extension of time through and including February 23, 2007, 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 Ernesto Martinez, respectfully requests this Court enter
an Order Granting Plaintiff a forty five (45) day extension of time to respond to Defendants’ Motion
to Dismiss up to and including February 23, 2008, and for such other relief as it deems necessary,
just and proper