Free Motion for Miscellaneous Relief - District Court of Connecticut - Connecticut

Case 3:00-cv-00052-RNC

Document 80

Filed 02/01/2005

Page 1 of 3

UNITED STATES DISTRICT COURT DISTRICT OF CONNECTICUT

MARGARET COWAN, as Administratrix of the Estate of Victoria Cooper, Plaintiff, V. MICHAEL BREEN, Defendant. CIVIL NO.: 3:000V00052(DJS) ALL CASES

MARGARET COWAN, as Administratrix of the Estate of Victoria Cooper, Plaintiff, V. TOWN OF NORTH BRANFORD Defendant. CIVIL NO.: 301CV00229 (DJS) JANUARY 28, 2005

JOINT MOTION REGARDING TRIALSCHEDULE The parties in this case jointly request the Court not to schedule this case for trial in March or April but to schedule it in May if possible, or as soon thereafter as the Court's schedule permits. The reason for this motion is that plaintiffs counsel has longstanding plans to be away on vacation for ten days beginning March 8, and defendants' counsel has longstanding plans to be away during April. Because this is a complex case that both sides have worked hard to prepare for trial, and that will require intensive preparation in the run-up to trial, counsel believe that it would be difficult to do the case justice if the trial were held between or shortly after those 1

Case 3:00-cv-00052-RNC

Document 80

Filed 02/01/2005

Page 2 of 3

vacations. These scheduling issues were discussed with Magistrate Judge Smith at the settlement conference last December but have not been the subject of a motion. Because this case has just been reassigned, counsel also believe that a status conference with the Court at the Court's convenience would be helpful.

THE PLAINTIFF By David N. Rosen 400 Orange Street New Haven, Connecticut 06511 (203) 787-3513 CT00196 E-mail: [email protected]

THE DEFENDANT

By ThiAu+' Thomas R. Gerarde, Esquire Howd & Ludorf 65 Wethersfield Avenue Hartford, Connecticut 06114 (860) 249-1361 CT5640 E-mail: [email protected]

/'7I d

RO

2

Case 3:00-cv-00052-RNC

Document 80

Filed 02/01/2005

Page 3 of 3

CERTIFICATE OF SERVICE I hereby certify that a copy of the foregoing Motion was sent first class mail, postage prepaid on January 28, 2005 to:

Thomas R. Gerarde, Esquire Howd & Ludorf 65 Wethersfield Avenue Hartford, Connecticut 06114

David N. Rosen

3