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

. Case 3:03-cv-01016-WWE Document 86 Filed O4/26/2004 Page 1 of 4
UNITED STATES DISTRICT COURT 2 O L ‘¥-·‘ `
DISTRICT OF CONNECTICUT {M ·*i{‘,? 9,
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JULIE DILLON RIPLEY MILLER, NO. 3 (€,QI@§’(]DFM) I
Plaintiff and Counterclaim I
Defendant, I
— against - I

MERRILL LYNCH CREDIT CORPORATION, i
April 23, 2004 I
Defendant and Counterclaimant. ‘
DEFENDANT’S MOTION TO AMEND THE SCHEDULE APPLICABLE TO I
DEFENDANT’S APPLICATION FOR PREJUDGMENT REMEDY
In furtherance of the efti cient administration of this proceeding, Defendant brings
this Motion to Amend the Schedule Applicable to Defendant’s Application for Prejudgment
Remedy (the "Motion to Amend"). Plaintiff consents to the granting of this Motion.
This is the first motion to amend the schedule applicable to Defendant’s
application for prejudgment remedy. Importantly, Defendant is not seeking to extend the dates
set by the Court for adjudication of Defendant’s Application for Prejudgment Remedy
("Defendant’s Application") M May 6, 20, 21 and 25, 2004. Rather, for the following reasons,
there is good cause to extend certain pre-hearing dates which will not impact the aforementioned
hearing dates.
First, the parties are currently seeking to negotiate a Stipulation which would
eliminate the need for any hearing on Defendant’s Application for Prejudgment Remedy. These
discussions are continuing and , if successful, will result in a more expeditious resolution of
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A Case 3:03-cv-01016-WWE Document 86 Filed O4/26/2004 Page 2 of 4 i
Defendanfs Application than a hearing on the merits. Defendant is still encouraged that such a
Stipulation may be possible.
Second, should the parties fail to negotiate a Stipulation to eliminate the need for
a hearing on the merits, Defendant requests additional time for the parties to stipulate to as many é
A facts and exhibits as possible and the parties believe that additional time is necessary to meet and
confer in good faith in this regard.
After reviewing this Motion, and finding good cause, the Court hereby ORDERS:
(i) A iifteen-day extension for the parties to meet and confer in an attempt to
arrive at stipulations of tact and to agree on exhibits that may be introduced
without objection;
(ii) A tifteen—day extension for the parties to file their respective memoranda of
law, stipulations of facts not in dispute, and list of exhibits that may be introduced
without obj ection; ,
(iii) The Amended Scheduling Order Dated April 2, 2004 shall otherwise remain
unchanged.
Hon. Donna F. Martinez l
United States Magistrate Judge {
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. ` Case 3:03-cv-01016-WWE Document 86 Filed O4/26/2004 Page 3 of 4 K
Dated: April 23, 2004
PAUL, HASTINGS, JANOFSKY &
WALKER LLP
By: { @ A
Douglas C. Conroy, ct11555
Thomas P. Friedman, ct24947
1055 Washington Boulevard
Stamford, CT 06901-2217
Telephone: (203) 961-7400
Facsimile: (203) 359-3031
Email: [email protected]
thomasfriedmangcbgaulhastingscqm
Dennis C. Fleischmann, ct11013
1290 Avenue of the Americas
New York, New York 10104
(212) 541-2000 1
. Counsel for Defendant and Counterclairnant
MERRILL LYNCH CREDIT
CORPORATION
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CERTIFICATE OF SERVICE
This is to certify that on this 23rd day of April, 2003, a copy of the foregoing Defendant’s
Motion To Amend The Schedule Applicable To Defendant’s Application For Prejudgment
Remedy was delivered via U.S. first class mail to:
Patrick W. Begos, Esq.
BEGOS & HORGAN, LLP
327 Riverside Avenue i
Westport., CT 06880 l
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Dennis C. Fleischmann, Esq.
Bryan Cave LLP
1290 Avenue of the Americas
New York, New York 10104
Thomas P. Friedmaii
STM1'272785.1
1141100021
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