Free Notice (Other) - District Court of Connecticut - Connecticut

F Case 3303-cv-O1O35€5lU Document 7 Filed 10/21 /2&Y§3 Page 1 or 3 I
UNITED STATES DISTRICT COURT I
?lEllEf$lr?lE?{Yrlft$El¥$FIT i... ORIGINAL I
STATE FARM FIRE AND CASUALTY-COl\/IIg(ANY
Index Na; soscvioss
Plaintiff,
—against- I
FIRST AMERICAN MOVING AND ._ I
DELIVERY SERVICE, INC. I Eg; ""§"§
Defendant. I 2
····························~·······················"········ X I ie I
WRITTEN STATEMENT BY COUNSEL i Hm
AS TO IWI-IY SANCTIONS SHOULD NOT BE IMPOSED —’ I
The undersigned, attorneys for the respective parties in the above-entitled
matter, respectfully request that the Court not impose sanctions for failure to comply
with District of Connecticut, Local Rule 38. I
The schedule of counsel for the defendant has been such over the past several
months that it has been difficult to arrange sufficient time to hold the necessary meeting I
or conference with other counsel that the Local Rule anticipates. The undersigned
Wishes to apologize to the Court for the inconvenience they may have caused by not
timely filing the Rule 26(f) report, previously. I
Additionally, there has been a dispute amongst the defendant’s various
automobile and general liability carriers as to who should cover and be responsible for I
this claim. To date, same has not been resolved. I
It was anticipated in working with the broker, Paul Della, that due to the unique
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. , Case 3:03-cv-01035@U Document 7 Filed 10/21/2053 Page 2 of 3 i
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nature of the damage to the Plaintiff's subregor, the office would be substituted as ,
counsel.
WHEREFORE, the undersigned parties respectfully request that the Court not l
order sanctions to any party in this matter.
Dated: Iericho, NY g
October 1, 2003 _` _ g
KE TH M. PIKEN (CT 12126) j
KENNETH M. PIKEN 8: ASSOCIATES
Attorneys for Plaintiff
333 Iericho Turnpike, Suite 218 i
Iericho, New York 11753 R
(516) 938-2300 (
CONSENT:
A/@7* @574/ mab
RICHARD]. SHAPIRO, ESQ.
Attorney for Plaintiff
P.O. Box 9177
Bridgeport, CT 06604
1
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Case 3:03-cv-O1035rSI§{U Document 7 Filed 10/21/2003 Page 3 of 3 N
1* r M Q)
UNITED STATES DISTRICT COURT
DISTRICT OF CONNECTICUT
--------------—-----------~------------------------...---.. x . I
STATE FARMS FIRE AND CASUALTY CO. Index No.: 303CV1035{$€1~K> I
Plaintiffs, i
CERTIFICATE OF SERVICE
-against—
FIRST AMERICAN MOVING AND ,
DELIVERY SERVICES, INC. '
Defendants.
........---.-..--.-..-.................-..................... X
DENISE R. CARCONE, hereby certifies that:
I am not a party to this action and am over the age of 18 years and reside in
Huntington, New York.
That on October 20, 2003, I served a copy of the annexed Written Statement by i
Counsel As to Why Sanctions Should Not Be Imposed in the above referenced matter. .
That I placed same in a post office official depository under the exclusive care
and custody of the United States Postal Service within the State of New York to
plaintiff's attorney last known address as indicated below:
Richard]. Shapiro, Esq.
Attorney for Plaintiff
P.O. Box 9177
Bridgeport, CT 06604
DENISE R, CARCONE