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

Case 3:03-cv-00636-J BA Document 70 Filed 02/1 1/2005 Page 1 of 2
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UNITED STATES DISTRICT COURT mg FEB I I pp 2: 5.1
DISTRICT OF CONNECTICUT
'C I COURT ‘
EVELINE GOINS : CIVIL ACTI8l§'Qg$I]S;]§{/Egq_ CT I
: 3:03 CV 636 (JBA) I
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JBC & ASSOCIATES, P.C. : I
JACK H. BOYAJIAN : ,
MARVIN BRANDON : FEBRUARY ll, 2005
UNOPPOSED MOTION TO AMEND SCHEDULE
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The defendants, with the consent of the plaintiff, hereby move to postpone the filing of i
the Joint Trial Memorandum, the pretrial conference and jury selection in the above matter until
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dates after March I2, 2005. The plaintiff s counsel advises that she is out of state caring for a
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newborn grandchild and does not have her files with her. Counsel’s absence and lack of access
to her files makes it difficult, if not impossible, to confer adequately about the Joint Trial
Memorandum. Moreover, the added attorney time to be invested in the matter prior to the i
settlement conference scheduled for March l, 2005 will make more difficult the task of reaching i
any settlement at that conference. In addition, the undersigned counsel’s contact person for the
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defendants is traveling, and the undersigned has had difficulty reaching the defendant in I
comiection with matters necessary to the preparation of the Joint Trial Memorandum.
This is the first motion by defendant directed to this recently established schedule and is
made with consent of the plaintiff s counsel. E
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A . Case 3:03-cv-00636-JBA Document 70 Filed O2/11/2005 Page 2 of 2 0
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Mmvm BRANDON
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By: . 0
Jonathan D. Elliot (Ct 05762)
Kleban & Sarnor, P.C.
2425 Post Road
Southport, CT 06490
(203) 254-8969
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CERTIFICATION
This is to certify that a copy of the foregoing has been mailed postage prepaid this 11m
day of February, 2005, to: 0
Joanne S. Faulkner, Esq.
123 Avon Street 0
New Haven, CT 06511
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Jonathan D. Elliot N

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