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

Case 3:03-cv-01023-JCH Document 16 Filed 04/28/2004 Page 1 of 2
UNITED STATES DISTRICT COURT
DISTRICT OF CONNECTICUT
X
DANIEL GORMAN, CIVIL ACTION
Plaintiff NO. 3:03CV1023 (JCH)
VS.
METRO—NORTH RAILROAD COMPANY,
Defendant APRIL 26, 2004
X
MOTION TO EXTEND DISCOVERY DEADLINE
The plaintiff hereby moves for a three week extension of time to complete
discovery from April 30 up to and including May 21, 2004.
In support hereof he states the following:
1. This is the first motion to extend the discovery deadline.
2. The plaintiff was deposed on March 16, 2004
3. There are two depositions of Metro—North employees that need to be
completed and they are currently scheduled for May 11, 2004.
4. Undersigned counsel contacted Metro-North's attorney, Patrick Flaherty, this
same day and he has no objection to the instant motion.

Case 3:03-cv-01023-JCH Document 16 Filed 04/28/2004 Page 2 of 2
Wherefore, the plaintiff seeks a three week extension of time to complete
discovery from April 30, 2004 up to and including May 21, 2004.
Respectfully submitted,
FOR THE PLAINTIFF DANIEL GORMAN,
By M
ott E. erry (ct17236)
CAHILL & GOETSCH, P.C.
I 43 Trumbull Street
New Haven, Connecticut 06511
(203) 777-1000
CERTIFICATE OF SERVICE
This is to certify that a copy of the foregoing was mailed, postage prepaid, on this
26th day of April, 2004, to Patrick J. Flaherty, Esq., Cooney, Scully and Dowling, Hartford
Square North, Ten Columbus Boulevard, Hartford, Connecticut 06106.
S@t E. Pe;ry
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