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

Case 3:03-cv-00623-SBD Document 21 Filed 02/13/2004 Page 1 of 3
UNITED STATES DISTRICT COU? m 3 R
DISTRICT OF CONNECTICUT p
( 3 {D 2i Ob l
KAREN HARTER, ; muh FEB {
Plaintiff E, Q aq-Tppnf {]()UR"l‘
: Civ. Aciitifr §§i;{$:@§QVG2.3(CFD)
v. : FEBRUARY 12, 2004 _
US INVESTIGATIONS I
SERVICES, INC., : ‘
Defendant [
PLAINTIFFS’ MOTION TO EXTEND DISCOVERY AND DEADLINE FOR l
FILING DISPOSITIVE MOTIONS l
Plaintiff Karen Harter hereby respectfully requests an extension of time to
complete discovery and file dispositive motions in this case, pursuant to Local Civil Rule
9(b). Plaintiff requests an additional ninety (90) days from the date the original deadline
for completion of discovery, as per the Scheduling Order [Endorsement Order dated July
l, 2003] The original deadline for completion of discovery is February 28, 2004. The
new deadline would be May 28, 2004.
Plaintiff also seeks permission to extend the deadline for filing dispositive
motions for ninety (90) days beyond April 30, 2004. The original deadline for filing
dispositive motions is April 30, 2004. The new deadline would be July 29, 2004.
ORAL ARGUMENT NOT REQUESTED i
TESTIMONY NOT REQUIRED I
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Case 3:03-cv-00623-@3}) Document 21 Filed O2/13/@4 Page 2 of 3
Plaintiff asserts that good cause exists for granting the instant motion: 1) the
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parties are currently engaged in settlement discussions before Magistrate Thomas Smith, i
and are scheduled to reappear on March 24, 2004 for a second session; 2) the parties have I
not engaged in any discovery and would like to exchange such discovery during the
proposed extended period of time to complete discovery; 3) the Court recently granted i
Defendant’s June 23, 2003 Motion to Strike on January 27, 2004 [Doc.# 15]; and 4) both
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parties are attempting to expedite the completion of discovery and file dispositive
motions in good faith. {
The undersigned has contacted counsel for the Defendant on February 12, 2004, t
who consented to the instant motion on this date.
This is Plaintiffs first request for an extension of time to extend the discovery and
dispositive motion deadlines.
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Dated: Southport, CT PLAINTIFF,
February 12, 2004 KAREN HARTER .
By: . _
Mark P. Carey _@;.: 28)
Carey & Associates, P.C.
Attorneys At Law -
7l Old Post Road, Suite One
Southport, CT 06490
(203) 255-4150 tel.
(203) 255-0380 fax.
[email protected]
Attorney for Plaintiff
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Case 3:03-cv-00623-QED Document 21 Filed 02/13/2004 Page 3 of 3 l
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canrmrcuiz or SERVICE
THIS IS TO CERTIFY, that the foregoing was delivered via UPS Second Day l
Service, postage prepaid, this the 12th day of February, 2004 to: l
Richard Voigt
McCa1·ter & English LLP
City Place I `
185 Asylum Street
Hartford, CT 06103
Mark P. Carey g g
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