Free Motion to Continue - District Court of Connecticut - Connecticut

Case 3:03-cv-00695-AVC Document 35 Filed O9/21/2004 Paget of 2
UNITED STATES DISTRICT COURT
DiSTRICT OF CONNECTICUT
:
Plaintiff, 3:03 CV 00695 (AVC)
vs. September 20, 2004
SUNBRIDGE HEALTHCARE
CORPORATION d/b/a :
l\/IEDIPLEX OF STAR/[FORD, :
Defendant.
MOTION FOR CONTINUANCE
As directed by U.S. Magistrate Judge Thomas P. Smith, Detendarat, Mediplex
Management, Inc. d/b/a Mediplex of Stamford (incorrectiy named herein as Sunbridge
Healthcare Corporation d/b/a Mediplex of Stamford) (hereinaher "Mediplex"), respectfully
moves this Court for an order that continues the currently scheduled September 29, 2004 heming
until October 20, 2004. In support of this Motion, Mediplex represents as follows:
l. On September l7, 2004, fudge Smith ordered a hearing scheduled for
September 29, 2004 at 10:00 a.m.
2. Later on September 17, 2004, the parties reached an agreement to settle
l the above—captioned litigation.
3. On September 20, 2004, the parties met before this Court to continn their
agreement to settle the above-captioned litigation.
4. The parties are in the process of rnemorializing the setttement agreement.

Case 3:03-cv-00695-AVC Document 35 Filed O9/21/2004 Page 2 of 2
5. On September 20, 2004, Judge Smith ordered the parties to tile the
appropriate closing papers with the clerk’s office within 30 days.
6. Thi.s is Defendant Medipiex’s first motion for a continuance.
7. P1aintiff’s counsel does not oppose this Motion.
WHEREFORE, for the reasons stated, Defendant Mediplex respecttiiliy moves
this Court for an Order that continues the hearing currently scheduled for September 29, 2004 to
October 20, 2004.
DEFENDANT
MEDIPLEX MANAGEMENT, INC. d/b/a
MEDIPI.-EX OF STAMFORD (incorrectly named
herein as SUNBRIDGE HEALTHCARE CORP.)
ey; ll Mat than sorted
Natasha C. Maynard
CT 25369 I
Margaret Armstrong Weiner
CT 18084
JACKSON LEWIS LLP
177 Broad Street
RO. Box 251
Stamford, Connecticut 06904-0251
Tel. (203) 961 —0404
Fax (203) 3244704
Email: ‘maynai·tiii(ri&iacksoniewiscorn
weinerin@]acl CERTIFICATION OF SERVICE
This is to certify that a copy of the foregoing has been served this day, postage
prepaid, to:
Thomas W. Bucci
Willinger, Willinger 8:; Bucci, P.C.
855 Main Street
Bridgeport, CT 06604
. te . ,. · __ ,- _
rl tf) dsftot. tr Kt at ’r;a.t6
Natasha C. Maynard
2