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

Case 3:03-cv—01010-JBA Document 29 Filed 03/23/2004 Pagef of4
UNITED STATES DISTRICT COURT
DISTRICT OF CONNECTICUT
CECIL YOUNG, :
Plaintiff, : CIVIL ACTION NO.
: 3:03CV1010 (JBA)
v. :
: Motion to Modify Report of the
CITY OF BRIDGEPORT HOUSING : Parties’ Planning Meeting
AUTHORITY, ET AL., :
Defendants. :
: March 22, 2004
MOTION TO MODIFY REPORT OF THE PARTIES’ PLANNING MEETING
Pursuant to FRCP Rule 7 and D. Conn. L. Civ. R 7(b), Plaintiff hereby files
this Motion for Modification ofthe Report of the Parties’ Planning Meeting.
After repeated rescheduling, a settlement conference was held on February 26,
2004. The City was of the opinion that having rehired the plaintiff, it had settled the
matter. As there was no agreement or release entered into by the plaintiff, that
purported settlement failed. Pending the settlement conference, discovery was
suspended bythe panties.
The parties request that the deadlines be extended as follows:
(a) Plaintiff should be allowed until l\/larch 30, 2004, to fiie motions
to join additional parties and until l\/larch 30, 2004, to file motions to amend the
pleadings.

Case 3:03-cv-01010-JBA Document 29 Filed 03/23/2004 Page 2 of 4
(b) Defendants should be allowed until April 30, 204, to file motions to
join additional parties and until April 30, 2004, tc serve a responsive
motion or pleading to the amended complaint, if filed.
(c) All discovery, including depositions of expert witnesses pursuant to
Fed. Fi. Civ. P. 26(b)(4), will be commenced immediately and
completed, not propounded, by August 27, 2004.
(d) Plaintiff will designate all trial experts and provide opposing counsel
with reports from retained experts pursuant to Fed. Fi. Civ. P.
26(a)(2) by May 21, 2004.
(e) Defendant will designate all trial experts and provide opposing
counsel with reports from retained experts pursuant to Fed. Fi. Civ.
P. 26(a)(2) by July 23, 2004.
(f) Depositions of Plaintiff’s experts to be completed by June 25, 2004.
(g) Depositicns of Defendants experts to be completed by August 27,
2004.
(h) A damage analysis wiil be provided by any party who has a claim or
counterclaim by May 21, 2004.
(i) Dispositive motions will be filed on or before October 27, 2004.
The Joint Trial Memorandum required by the Standing Order on
Trial Memoranda in Civil Cases will be filed within sixty (60) days
after the entry on the ruling on the last dispositive motion. if
dispositive motions are not flied, the joint trial memorandum
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Case 3:03-cv-01010-JBA Document 29 Filed 03/23/2004 Page 3 of 4
required by the Standing Motion on Trial Memoranda in Civil Cases
will be filed within sixty (80) days after the completion of all
discovery.
(j) The case will be ready for trial within sixty (60) days after the filing
of the Joint Trial Memorandum.
This is the first request for modification. Plaintiff has sought the consent of
Defendants and Defendants have consented to the modification. The instant case
is not assigned for trial.
PLAINTIFF,
CECIL YOUNG
/ // R nw
By; Q [
Elisabeth Seieroe Maurer (ct11445)
Law Offices of Elisabeth Seieroe Maurer, PC
871 Ethan Allen Hwy., Suite 202
Ridgefield, CT 08877
Phone (203) 438-1388
_ Fax (203) 431-0357
e-mail: [email protected]
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Case 3:03-cv-01010-JBA Document 29 Filed 03/23/2004 Page 4 of 4
CERTIFICATE OF SERVICE
I hereby certify that a copy of the foregoing Motion to Modify the Report of
the Parties’ Planning Meeting and Status Conference Memorandum has been sent
via facsimile on this 22““’ day of March 2004 to the following counsel and pro se
parties.
Barbara Brazzel-Massaro
Associate City Attorney
Office of the City Attorney
999 Broad Street, 2nd Floor
Bridgeport, CT 06604
James Mahar, Esq.
Ryan, Ryan, Johnson & DeLuca, LLP
B0 Fourth Street
Stamford, CT 06905
éhsabeth Seieroe Maurer/P
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