Case 3:03-cv-01053-AVC
Document 9
Filed 08/02/2004
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UNITED STATES DISTRICT COURT DISTRICT OF CONNECTICUT
MARK CROFUT, Plaintiff, v. UNITED STATES OF AMERICA, Defendant.
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Civil No. 3:03CV1053 (AVC)
August 2, 2004
MOTION FOR EXTEND DISCOVERY DEADLINES SET FORTH IN THE SCHEDULING ORDER Pursuant to Local Rule 7(b) of the Local Rules of Procedure for the District of Connecticut, the Defendant, United States of America, hereby respectfully requests a sixty (60) day extension of time from August 1, 2004 to October 1, 2004 within which to designate its expert witnesses. This additional time is requested because counsel for the plaintiff has recently advised counsel for the defendant that he has been unable to respond to the Interrogatories and Request for Production of Documents, responses to which were due on June 21, 2004. Without that information including medical and treatment records of the plaintiff, the defendant has been unable to depose the plaintiff. The information gathered from the discovery responses as well as the plaintiff's deposition will be needed in order for an expert witness to render an opinion.
Case 3:03-cv-01053-AVC
Document 9
Filed 08/02/2004
Page 2 of 3
This is the first motion to extend this time limitation. Counsel for the plaintiff has indicated that he has no objection to the granting of this motion. Respectfully submitted, KEVIN J. O'CONNOR UNITED STATES ATTORNEY
BY:
___________________________________ WILLIAM A. COLLIER ASSISTANT UNITED STATES ATTORNEY
FOR:
BRENDA M. GREEN ASSISTANT UNITED STATES ATTORNEY FEDERAL BAR NO. CT19538 UNITED STATES ATTORNEY'S OFFICE 915 LAFAYETTE BOULEVARD, ROOM 309 BRIDGEPORT, CT 06604 (203) 696-3000 (telephone) (203) 579-5575 (facsimile) [email protected]
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Case 3:03-cv-01053-AVC
Document 9
Filed 08/02/2004
Page 3 of 3
CERTIFICATION OF SERVICE This is to certify that a copy of the within and foregoing Motion for Extend Discovery Deadlines Set Forth in the Scheduling Order has been mailed on the 2nd day of August, 2004, to: John Pirina, Jr., Esq. Law Offices of Arnaldo J. Sierra 215 Washington Street Hartford, CT 06106 ___________________________________ WILLIAM A. COLLIER ASSISTANT UNITED STATES ATTORNEY
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