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

Case 3:00-cv-00052-RNC

Document 77

Filed 12/22/2004

Page 1 of 2

UNITED STATES DISTRICT COURT DISTRICT OF CONNECTICUT MARGARET COWAN, ADMINISTRATRIX OF THE ESTATE OF VICTORIA COOPER v. MICHAEL BREEN : : : : : : :

NO.: 3:00 CV 0052 (DJS)

MARGARET COWAN, ADMINISTRATRIX OF THE ESTATE OF VICTORIA COOPER v. NORTH BRANFORD

: : : : : : :

NO.: 3:01 CV 0229 (DJS)

DECEMBER 21, 2004

MOTION FOR ENLARGEMENT OF TIME TO FILE JOINT TRIAL MEMORANDUM The plaintiff, Margaret Cowan, Administratrix of the Estate of Victoria Cooper, and the defendants, MICHAEL BREEN and TOWN OF NORTH BRANFORD, hereby move on consent for an enlargement of time up to and including January 31, 2005 in which to file the joint trial memorandum in the above captioned matter. The parties also move for an order setting the deadline to file motions in limine pertaining to this case to February 28, 2005. In support of this Motion, the parties offer as follows: 1. This matter was recently the subject of settlement of a settlement conference before Magistrate Judge Thomas P. Smith; 2. While the matter did not resolve, the parties focused their attention on the last items necessary for the adjudication of this matter;

Case 3:00-cv-00052-RNC

Document 77

Filed 12/22/2004

Page 2 of 2

3.

The possibility of settlement and the proximity of the holidays prevent the parties from completing the joint trial memorandum as currently ordered to be so by December 30, 2004;

4.

This case is extraordinarily complex matter and good cause exists for this extension of time.

WHEREFORE, the parties pray that the Court grant this motion THE DEFENDANTS, MICHAEL BREEN and TOWN OF NORTH BRANFORD

/s/John J. Radshaw, III John J. Radshaw, III, ct19882 HOWD & LUDORF 65 Wethersfield Avenue Hartford, CT 06114 (860) 249-1361 (860) 249-7665 (fax)

CERTIFICATION This is to certify that a copy of the foregoing has been sent, handling charges prepaid, via U.S. Mail to the following counsel of record this 21th day of December, 2004 David N. Rosen, Esquire Rosen & Dolan, PC 400 Orange Street New Haven, CT 06511

/s/John J. Radshaw, III John J. Radshaw, III

2