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

F . _ Case 3:03-cv-01016»NWE Document 66 Filed 03/17/2004 Page 1 of 4
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UNITED STATES DISTRICT COURT
_ _ DISTRICT OF CONNECTICUT mm,
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i RIPLEY MILLER, NO-
1 Plaintiff and Counterclaim
i p Defendant,
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i — against -
MERRILL LYNCH CREDIT CORPORATION, l
March 5, 2004 ,
Defendant and Counterclaimant.
JOINT MOTION TO AMEND PRE-TRIAL SCHEDULE \
Whereas the parties to this action diligently have conducted discovery in good [
faith, and have sought to complete discovery by the deadline of March 15, 2004, including i
nineteen depositions since the inception of this action;
Whereas the parties have filed three previous motions to amend the pre-trial
schedule. The first two motions sought extensions only of certain intermediate pre~trial *
deadlines, without extending the discovery cut-off date. The third motion, tiled December l 1,
2003 sought.an extension of the discovery cut-off to either February 13, 2004 (as requested by
defendant) or thirty days after the Court ruled on plaintiff’ s December 3, 2003 motion to compel
(as requested by plaintiff`). By order dated December 22, 2003, the Court extended the discovery
cutoff to March 15, 2004. i
Whereas certain bona fide discovery disputes have delayed the discovery
process, resulting in the filing of a motion to compel by each party ("Motions to Compel") which E
were argued before this Court on January 20, 2004 and remain sub judice;
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Case;03-cv-01016-WWE Document 66 Filed OS/17/2004 Page 2 of 4
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i Whereas the parties agree that discovery cannot be completed prior to the Court’s
rulings on the parties’ Motions to Compel; i
Whereas the parties each have depositions to conduct that they believe in good n
faith are material to the proper adjudication of this action and cannot be completed by March 15,
2004 despite the best efforts of counsel, including the Plaintiff s deposition, which has been
l recessed pending the Court’s ruling on Defendant’s Motion to Compel the production of
additional documents;
_ 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
April 30, 2004;
(ii) That the Joint Trial Memoranda will be tiled by May 31, 2004;
(iii) That the case be placed on the Trial Ready List for June, 2004.

United States Magistrate Judge

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- ‘ · Case 3:03-cv-OKONY-Vv§WE Document 66 Filed a /Q}/$004 Page 3 of 4
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Dated: March 4, 2004
I BEGOS & HORGAN LLP PAUL, I-IASTINGS, JANOF SKY & I
` I WALKER LLP
i By: By: ·"/09*
, Patrick W. Begos, ct190 0 Douglas C. Conroy, ct11555
I Christopher G. Brown, ct 18216 Thomas P. Friedman, ct24947
K 327 Riverside Avenue 1055 Washington Boulevard
, Westport, CT 06880 Stamford, CT 06901-2217
Telephone:(203) 226-9990 Telephone: (203) 961-7400
I Facsimile:(203) 222-4833 Facsimile: (203) 359-3031 i
l Email: [email protected] Email: [email protected] I
[email protected] [email protected] ,
Counsel for Plaintiff and Counterclaim Counsel for Defendant and Counterclaimant `
Defendant MERRILL LYNCH CREDIT `
JULIE DILLON RIPLEY MILLER CORPORATION E
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i - Case 3:03-cv-O1016;WWE Document 66 Filed O3/17/2004 Page 4 of 4 r
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CERTIFICATE OF SERVICE
This is to certify that on this L th day of March 2004, a copy of the foregoing JOINT
MOTION TO AMEND PRE-TRIAL SCHEDULE was delivered via U.S. first class mail to:
Patrick W. Begos, Esq.
BEGOS .& HORGAN, LLP
327 Riverside Avenue
Westport, CT 06880
i Thomas P. Friedman {
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