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

_ ase 3:03-cv-00648-MRK Document 25 Filed O4/26/20 4 Page 1 of 3 p
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UNITED STATES DIST TCT COUR J -: ~.,g I
DISTRICT OF CONNECTICUT
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BIIAN ALMASSIAN, Ph.D. l
Plaintiffs i
VS. CIVIL ACTIO NO.
3:03 CV 648 RK E
CAROLYN R. KAHN, [ I
Defendant APRIL 23, 20 I 4 .
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The defendant hereby requests an extension of time of the heduling order as it relates to
the tiling of dispositive motions. The defendant requests an extensiol of time of thirty (30) days for
the filing of dispositive motions. The defendant requests that new da e for filing dispositive motions
be changed to June 1, 2004. In support of same, the defendant offers he following:
1) This is the first such request for extension of time rel tive to the deadline for filing
dispositive motions. _ . is '
2) The undersigned has contacted Attorney John William counsel for the plaintiff and
Attorney Williams has no objection to this extension of time.
3) There is good cause for the extension of time due to the fact that the plaintiff was only
recently deposed on April 20, 2004. The reason for the late deposi on is that during March when
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_ - ase 3:03-cv-00648-MRK Document 25 Filed 04/26/20 4 Page 2 of 3
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the deposition was previously scheduled, the plaintiffs wife was e periencing medical difficulties
and was facing a surgery. Accordingly, the plaintiff requested that e deposition be rescheduled to
mid-April in order to allow him to be with his wife and assist her ith recuperation following that
surgery. The undersigned complied with that request and therefo the deposition could not be
taken until April 20, 2004.
4) The plaintiff, as is his right, requested the opportunity t l read and sign the transcript of
the deposition. Accordingly, there will be a 30-day delay in obtainin the final transcript which will
be necessary for support and attachment to a dispositive motion. l
Therefore, the defendant requests that the court grant this tension of time changing the
deadline for filing dispositive motions, including all motions to pre lude expert testimony, to June
1, 2004. In addition, that would cause the deadline for filing a joint In 'al memorandum to be moved
to July 1, 2004.
THE DEFEND * T |/
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,¤ e, von K ,Brady & Fries, LLC
9 9 Oronoque ane
Stratford, CT 0 614
Telephone — (2 3) 378-7100
Fax — (203) 37 -7711
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( =» ase 3:03-cv-00648-MRK Document 25 Filed 04/26/20 4 Page 3 of 3


This is to certify that a copy of the foregoing has been sent, ia U.S. mail, postage prepaid, l
this 23rd day of April, 2004, to: i
John R. Williams, Esquire
51 Elm Street
New Haven, CT 06510
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Co Brady & Fries, LLC
9 9 Oronoquell ane
P tratford, CT 6614
rcicpimc - (2 3) 378—7l00
Fax - (203) 3 -7711
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