Free Response - District Court of Connecticut - Connecticut

m_mmMm_W I
Case 3:03-cv-01040:PCD Document 14 Filed O2/20[ O04 Page 1 of 3 I
1 I
I M Ln I
r . @0
I EU Q .,.. a
if- ff/ti ·~»l 1
t.r;'S gh fil
UNITED STATES DISTRICT CO RIF I—{—j§,"‘ _¤>‘.i;,;,·_._ P -
DISTRICT OF CONNECTICU ' C@ri·;,,QI ’
JOSEPHINE SULLIVAN ;
Plaintiff, : CIVIL AC ION NO. I
: 3:03cv104 (PCD) I
V. I I
CARSON PRODUCT, I
DEVELOPMENT, INC.,ET AL : FEBRUA 19, 2004 I
` Defendant I
I
COUNSEL STATEMENT RE: RULE 2 FILING
In accordance with the clerk’s Notice to Counsel issue relative to the delayed filing of
the Rule 26(f) Report, counsel represent as follows:
1. This action was originally returned to the Superi r Court for the Judicial District of
New London at Norwich bearing return date of June 17, 2003.
2. On or about June 11, 2003, defendant removed the case to Federal Court based
on federal question jurisdiction and diversity of citizenship. I
3. On or about December 16, 2003, plaintiff filed h r initial disclosures. I
4. On January 28, 2004, a settlementfstatus confe ence took place before PJO
Lawrence lanriotti.
I
5. At that time, the parties were unable to settle th s case, but did engage in I
scheduling discussions.
6. lt was agreed that the 26(f) statement would be filed by February 6, 2004, and I
certain additional discovery would be commenced. The 26(f) tatement was in fact filed with the
court on February 6, 2004, and plaintiff has commenced his di covery.
I
I
LAW OFFICES OF I
CICCHIELLO Sc CICCHIELLO LLC
582 WEST MAIN STREET - NORWICH, CONNECTICUT 06360 · (860) 886-93OO
I

M
Case 3:03-cv-O104l¤O=)PCD Document 14 Filed O2/204 004 Page 2 of 3
\.._, 5 I
7. The parties have acted dilligently with respect ·· prosecution and defens-e ofthe
claims, especially in iight of the complex nature of the claims a d defenses. I
8. An oversight by pIaintiff's counsel resulted in th =- failure to file the Rule 26(f)
report. The press of business and several state courtjury sele tions and trials during the last
I
quarter of 2003 occupied plaintiffs counsel’s time. State court jury selection typically absorbs
four days each with evidence and argument taking an addltion l two days.
5
9. Upon conclusion ofthe settlement/status confe nce, counsel immediately
conferred and prepared a Rule 26(f) Report. The same has b en filed in accordance with the
_ terms of the status conference.
10. It is respectfully requested that sanctions not en er in this matter as counsel have
not been neglectful ofthe case and have proceeded diligently n dealing with the claims and
l
issues.
THE PLAlNTlFF, I
JOSEPHINE SUL .· l< ll·l·- I I
- /" l
ev: I _. l
lv " r lo ct0927? I
• =· .ci [email protected]
Cicchiello ·i Cicchiello l
582 West ain Street
Norwich, T 06360 I
860-886-9 00 phone i
860-886-5 63 fax l
Her Attorn y
l
I
l
l
LAW OFFICES OF
CICCHIELLO Be CICCHIELLO 1.i.c I
582 WEST MAIN STREET - NORWECH. CONNECTICUT 05360 - (860) 886-9300
l
. l

Case 3:03-cv-01040>PCD Document 14 Filed 02/20A 004 Page 3 of 3
I
I
cERTIr=IcATIoM I I
I hereby certify that a copy of the foregoing was mailed to all counsel of record and pro I
se parties on February 19, 2004. I
Daniel Kalish, Esq. ¤
Wiggin 8. Dana LLP I
One Century Tower i
P.O. Box 1832
New Haven, CT 06508-1832
I
I .-- I
E I
L chi llo
I
I
I
I
I

I
I
I
LAW OVFICES OF
Gucci-IIELL0 Be Clccl-IIELL0 1.1.c I
582 WEST MAIN STREET 7 NORWICH, CONNECTICUT 06360 · (850) 8136-9300 \
g I
I
I

I

I