Free Motion for Extension of Time - District Court of Connecticut - Connecticut

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Case 3:00-cv-00650-CFD Document 97 . Filed 1 1/07/ 003 Page 1 of 3
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UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF %ONNECTlCUT 5 H gm D
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CONSTITUTION STATE CHALLENGE, INC. and 1 )
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O ASTERN OPEN INVITATIONAL, INC. p g CIV gl U R T
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Plaintiffs l ) 3:00 CV 650 (CFD) `
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v. ) ‘
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JOHN NYMCHEK I ) ,
CATHI NYMCHEK 1 ) Nov ber 6, 2003
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Defendants I )
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REQUEST FOR CON I INUANCE i
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Constitution State Challenge, Inc. and Northeasterni Open Invitatio al, Inc., Plaintiffs in the I
above matter, represent t0 this Court as follows:
l. This is a pending civil matter scheduled for trial to the Cou (Droney, J.) to start on ~
December l, 2003.
2. At a Pretrial Status Conference meeting hel i on this matter o October 29, 2003 the
Court assigned this matter to Magistrate Jud e Thomas Smit for the purpose of
conducting additional settlement discussion p. E
3. Pursuant to the Court’s directives of Octobepi 29, 2003 the P ies and their counsel
met with Judge Smith on November 3, 2003pfrom 2:00 P.M. o 5:30 P.M.
4. Although no settlement agreement emerged i om the settlem t conference of
November 3, 2003 the Parties did, in the opi `on of the under igned, make substantial
progress in bridging several of the gulfs that had separated th m when previous
attempts were made at settlement.
5. The undersigned, lead counsel for Plaintiffs,ihas been in regu ar contact with the
office of Judge Smith since November l so as to keep Judge mith apprised of
subsequent developments in attempts to settlle this matter.
6. Judge Smith has assigned this matter for a iiirther settlement onference to take place i
on December l, 2003 at 10:00 A.l\/I.
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Case 3:00-cv-006506%: D Document 97 p Filed 1 1/07é O3 Page 2 of 3
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7. The undersigned suggests to the Court the ii practicality of dhering to the currently
scheduled trial dates when the Parties will e holding additi nal settlement meetings
the day trial is scheduled to start, to wit: th more time the P rties spend between
t0day’s date and December 1 preparing for rial the less inc tive there will be on
December l to resolve the matter by settlenient rather then b litigation.
8. At the October 29 Pretrial Status Conferende the Court requ sted that both Parties
have their trial exhibits marked and submittizd to the Court (i duplicate) by t0day’s
date.
n 9. Due to the substantial amount of time expe ded by the unde signed between October \
29 and today’s date in settlement meetings, egotiations and iscussions, the =
undersigned has been unable to get all of Pl intiffs exhibits repared for marking and
pretrial submission to the Court.
WHEREFORE, for the reasons as recited hereinabovd, it is requested t at the Court issue the
following orders in this matter.
1. That the trial dates in this matter be postponizd to sometime 0 or after February 9,
2004} p
2. That absent a settlement in this matter reacljid on or before ecember l, 2003 that l
the date for submittal of trial exhibits for m p king be postpon d to December 8, 2003. I
Dated at Hartford, CT this 6th day of November, 2003. p
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Pitlimrrrs
Bw Their Attorney
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(/@)•"\ (Y\ . Q., ’
Le n M. Kaatz
ll Oak Street
H ford, CT 0610
86 -247-5640
Fe p eral Bar No. O0 36
I Plaintiff’ s are presently deeply entrenched in preparations for the iNortheastem Open vitational Dance
Competition which will take place the weekend of January 30, 2006.
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l Case 3:0O—cv-0O650(·G§D Document 97 Filed 11/07/ (503 Page 3 of 3
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CERTIFICAT ON
I hereby certify that a copy of the foregoing ha been mailed po age prepaid and/or hand
delivered to Mr. and Mrs. John and Cathi Nymchek (by email attachm t) and to Attorney John
Linderman (by email attachment), and to the Honorabl? Thomas P. Smi , United States District
Court House, 450 Main Street, Hartford, CT 06103 on( or before the 6th day of November, 2003.
, lLeon M. Kaatz
Commissioner 0 the Superior Court
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