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

Case 3:03-cv-00630-DJS Document 126 Filed 11/30/2006 Page 1 of 4
UNITED STATES DISTRICT COURT
DISTRICT OF CONNECTICUTT
MARIO RICHARDS,
: CIVIL ACTION NO:
Plaintiff, :
v. 3:03 CV 00630 (DIS)
COMPUTER SCIENCES CORPORATION,
: NOVEMBER 30, 2006
Defendant. :
JOINT MOTION FOR EXTENSION OF DISCOVERY
ANI) DISPOSITIVII`. MOTIONS DEADLINES
Pursuant to the Federal Rules of Civil Procedure and the Local Rules of
this Court, the Plaintiff, Mario Richards and Defendant, Computer Sciences Corporation,
hereby respectfully move for an extension of the deadlines for completing discovery and
for tiling dispositive motions. The Parties request that the deadline for discovery be
extended 90 days from November 30, 2006 to February 28, 2007 and that the deadline for
dispositive motions also be extended from December 29, 2006 to March 30, 2007.
In support of this Motion, Defendant states as follows:
l. On June 5, 2006, this court set deadlines for discovery to be completed by
November 30, 2006 and dispositive motions to be tiled by December 29, 2006 These
deadlines were set following a status conference wherein the parties expressed their
desire to try to settle the case at a settlement conference on August 2, 2006, but would
need time to complete discovery in the event the case does not settle.

I Case 3:03-cv-00630-DJS Document 126 Filed 11/30/2006 Page 2 of 4
2. The settlernent conference was held on August 2, 2006, however, the
parties were unable to reach an agreement to settle. This was based in part on the fact
that Plaintifl”s counsel had not yet received information he requested from all of the opt
ins relating to their alleged hours worked.
3. Another status conference was held on August 9, 2006 and thereaner the
Court issued an Order to the opt ins requiring that they respond to the requests for
information regarding hours by October l9, 2006,
4. Piaintiff’s counsel has received additional responses and has informed
Defendanfs counsel that he is in the process of finalizing a settlement demand.
Plaintiffs counsel anticipates getting a settlement demand to Det`endant’s counsel by
December I, 2006 or shortly thereafter.
5. The l’arties intend to engage in good faith negotiations to try to resolve
this matter and require additional time to do so. As such, the parties move the Court to
extend the currently pending deadlines for discovery and dispositive motions so that they
may attempt to resolve the case without expanding additional resources on discovery and
motion practice.
.2

Case 3:03-cv-00630-DJS Document 126 Filed 11/30/2006 Page 3 of 4
WHEREFORE, the Parties request that the deadline for discovery be extended 90
days from November 30, .2006 to February 28, 2007 and that the deadline for dispositive
motions also be extended from December 29, 2006 to March 30, 2007,
PLAINTIFF DEFENDANT,
MARIO RICHARDS COMPUTER SCIENCES CORPORATION
By: /s/ Mic/mel J Me/ly By: /5/ T czsos C. Pczindiris
Michael J. Melly, Esq. (ct I7841) Tasos C. Paindiris, Esq. (ct 16739)
M3 Oneeo Avenue #4 Jackson Lewis LLP
P.O. Box 77I 90 State House Square, Sm Fleer
New London, CT 06320 Hartford, CT 0610.3
Tet: 860447-I990 Tel: 860»522—0404
Fax: 860~24”/-1330
E~mai1: pai11dirt@jael 3

Case 3:03-cv-00630-DJS Document 126 Filed 11/30/2006 Page 4 of 4
CERTIFICATION OF SERVICE
I hereby certify that on November 30, 2006, a copy of the foregoing Joint
Motion for Extension of Time was tiled electronically and served by mail on anyone
unable to accept electronic tiling. Notice of this tiling will be sent by e~maii to all parties
by operation of the Court’s eiecttonic filing system and by mail to anyone unable to
accept electronic tiiing as indicated on the Notice of Electronic Filing. ?arties may
access this filing through the Court’s CMECF System.
/s/ Tczsos C. Pcrindiris
Tasos C. Paindiris