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

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UNITED STATES DISTRICT COURT QFFELIT gy Um, I
DISTRICT OF CONNECTICUT ~ r- ·.r ORD. C _
DOLORES FONSECA, ET AL : DIV. NO. 3:03 CV1055(AVC)
Plaintiff :
Vs. :
JASON ALTERIO, ET AL :
I Defendants : FEBRUARY 25, 2004
MOTION FOR EXTENSION OF TIME OF THE SCHEDULING ORDER
The Defendants, City of Bridgeport and Jorge Larrequi, respectfully request
that the Court extend the Scheduling Order in this action to permit the discovery
period to be extended until April 30, .2004, to complete the depositions in the action,
and until ll/lay 14, 2004, for deposition notices. ,
ln support of this motion, the parties state:
1. There have been numerous depositions in this action to date. The
defendants began the depositions of the plaintiffs and some of the plaintiffs
witnesses. The defendants were unable to complete the depositions of the plaintiffs,
Rafael 8. Dolores Fonseca, although started additionally, the defendants have
scheduled depositions of Rafael Fonseca and Dolores Fonseca, Annie Ortiz and
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{ P V Case 3:O3—cv-O10@VC Document 33 Filed O2/3?j‘§OO4 Page 2 of 3
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David Uliano on several occasions but they have been cancelled by the plaintiffs
counsel because he was unable to attend.
2. The defendants have also attempted to contact and locate some of the
g pIaintifl"s witnesses and have had difficulty because plaintiff does not have current
{ addresses.
3. Lastly, the defendants have requested to have access to the site of the
arrest, which is plaintiffs home to take pictures and do measurements because of the
plaintiffs lack of knowledge in her deposition testimony but have not had a date
agreed upon by the plaintiffs.
Once the depositions are completed, the defendants believe that a
dispositive motion may be appropriate, but needs to complete the depositions to make ,
a determination.
4. The defendants have contacted all counsel and they have no objection
and join in the Motion for Extension.
5. This is the First Request for an Extension of the Scheduling Order `by
the parties.

Case 3:03-cv-010%5qAVC Document 33 Filed 02/27[2004 Page 3 of 3
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THE DEFENDANTS
Jorge Larrequi and City of Bridgeport
Barbara Brazzel-Illlassaro
_ Assistant City Attorney
g OFFICE OF THE CITY ATTORNEY
999 Broad Street- 2"°' Floor
Bridgeport, CT 06604
Telephone: 203-576-7647
Juris No. 06192
QERTIFICATION g
This is to certify that a copy of the foregoing was mailed, postage prepaid, on
this 25"‘ day of February, 2004, to:
William Barnes, Esq.
1100 Kings Highway
Fairfield, CT 06824
. John Kelly & Diane Benevides
¤ Cantor, Floman, Gross, Kelly
& Sacramone, P.C.
378 Boston Post Road
Orange, CT 06477

Barbara Brazzel-Massaro
Commissioner of the Superior Court
H:Misc.BBM.Fonseca.lVlotionExtTime