_» _ Cir; 3:03-cv-O101$5;_WWE Document 74 Filed O3/gi/ZGUZCU P>.;l§él"I I'H`f‘,?
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III I UNITED STATES DISTRICT COURT I
mu MAR p 12: 2 LI DISTRICT OF CONNECTICUT muh MAR I III A [Q: 20
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Plaintiff and Counterclaim bg,}/WJ I
Defendant, ,
- against - I
MERRILL LYNCH CREDIT CORPORATION,
March 5, 2004
Defendant and Counterclaimant.
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lg JOINT MOTION TO AMEND PRE-TRIAL SCHEDULE
Q QI! Whereas the parties to this action diligently have conducted discovery in good
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& fh faith, and have sought to complete discovery by the deadline of March 15, 2004, including
Im p T nineteen depositions since the inception of this action;
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\ < _ { . Whereas the parties have filed three previous motions to amend the pre-trial
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QS I I schedule. The first two motions sought extensions only of certain intermediate pre-trial
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Q deadlines, without extending the discovery cut-off date. The third motion, filed December ll,
>% § 2003 soughttan extension of the discovery cut—off to either February 13, 2004 (as requested by
II" defendant) or thirty days after the Court ruled on plaintiff s December 3, 2003 motion to compel
(as rediuiested byplaintiff). By order dated December 22, 2003, the Court extended the discovery
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utof@p M"?To.b.:l5, 2004. ‘
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LL! ifi §;IWhereas certain bona fide discovery disputes have delayed the discovery
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Eaarocg, in the filing of a motion to compel by each party ("Moti0ns to Compel") which
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wer§guedjbefore this Court on January 20, 2004 and remain sub judice;
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» Case 3:03-cv-01016-WWE Document 74 Filed O3/26/2004 Page 2 of 2 ___
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I Whereas the parties agree that discovery cannot be completed prior to the Court’s
l rulings on the parties’ Motions to Compel;
X Whereas the parties ea·ch have depositions to conduct that they believe in good
l faith are material tothe proper adjudication of this action and cannot be completed by March 15,
A 2004 despite the best efforts of counsel, including the Plaintiff’ s deposition, which has been J
recessed pending the Court’s ruling on Defendant’s Motion to Compel the production of g
additional documents; U
Accordingly, the parties respectfully request that the Court extend the discovery
cut·off date until April 30, 2004 as well. as corresponding pre-trial dates for an equivalent period
of six weeks pursuant to Fed. R. Civ. Proc. 6(b) and Local Civil Rule 9(b).
After reviewing the Joint Motion, and finding good cause, the Court hereby
ORDERS:
(i) That the Discovery Cut-Off is extended from March 15, 2004 to i
April 30, 2004; R
(ii) That the Joint Trial Memoranda will be file by May 31, 2004;
(iii) That the case be placed on the Trial iadgist @1%)04. l
A bH'on.’D*onna FJlVlartinez I - #-R
United States Magistrate Judge