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

Case 3:03-cv-01055-AVC

Document 61

Filed 06/09/2005

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UNITED STATES DISTRICT COURT DISTRICT OF CONNECTICUT DOLORES FONSECA, RAFAEL FONSECA and MELANIE FONSECA, a minor, ppa, Plaintiffs, v. JASON ALTERIO, a Bridgeport police officer, in his individual capacity; JORGE LARREGUI, a Bridgeport police officer, in his individual capacity; and the CITY OF BRIDGEPORT, a municipal corporation, Defendants. : JUNE 8, 2005 : : : : : : : : DOCKET NO. 03-CV-1055 (AVC)

MOTION AGREED UPON BY ALL PARTIES TO RESET PRETRIAL DEADLINES The undersigned, hereby respectfully move upon agreement of all parties for an order resetting the pretrial deadlines in this case: 1. 2. 3. Discovery to be completed by August 8, 2005. Dispositive motions to be filed by September 7, 2005. Trial memorandum to be filed thirty days after

September 7, 2005 of the decision on the dispositive motions. The grounds for this motion are that Defendant Alterio has recently changed counsel and his new counsel, Elliot Spector, Esq. needs time to become familiar with the file and do such discovery he needs to create a record. In addition, for health

Case 3:03-cv-01055-AVC

Document 61

Filed 06/09/2005

Page 2 of 2

reasons present counsel for plaintiffs, William Barnes, is transferring the file to Attorney Diane Polan, who will likewise need time to familiarize herself with the file and take whatever discovery she deems necessary to complete the record. The above schedule was discussed with PJO Reed Murphy at a conference held June 7, 2005. PJO Murphy approved the schedule. THE PLAINTIFFS DOLORES FONSECA, ET AL

____________________________ WILLIAM B. BARNES, ESQ. (CT00268) Rosenstein & Barnes 1100 Kings Hwy. East, Fairfield, CT 06825 (203) 367-7922

CERTIFICATION A copy of the foregoing was mailed first class mail, postage prepaid, on June 8, 2005 to: Barbara Brazzel-Massaro, Esq. Associate City Attorney Office of the City Attorney Bridgeport City Hall Annex 999 Broad St. Bridgeport, CT 06604 Elliot Spector, Esq. Noble, Spector, Young & O'Connor One Congress Street Hartford CT 06114

_____________________________ WILLIAM B. BARNES, ESQ.

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