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

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Case 3:03-cv-01009-SRU Document 67 Filed 12/22/2004 Page 1 of 3 I
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UNITED STATES DISTRICT C(DiHgIll§§—”[]§{'I`, IIIIIEII
ggsrmcr or CONNECTICUT I
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JOSEPH Arms Ss HAIM ATTIAS z CIVIL N0. 303 cv 01009 (SRU) “ I
Plaintiffs : I I I
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PATRONS MUTUAL INSURANCE I I I I
COMPANY or CONNECTICUT I I I
Defendant 2 DECEMBER 21, 2004 I
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PLAINTIFFEP MOTION Fon ENLARGEMENT
on TIME Fon SCHEDULING oimmzs
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The Plaintiffs Joseph & Haim Attias, hereby request through their counsel for an ‘
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enlargement of time until February 15, 2005 in regards to the scheduling orders entered
into by the Court on or about October 20, 2004 for the following reasons:
l. The parties had previously agreed to the defendant’s Motion for I I
Enlargement of Time dated October 18, 2004. _ I I
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2. Said motion requested forty—day enlargement on the previous orders I I I
thereby setting the pertinent deadlines as follows: I I
a. Dispositive Motion filed by 12/ 15/04 I
b. Joint Trial Memorandum field by l2/15/04
3. The parties have several unresolved motions with respect to various
discovery issues not yet addressed by the court I I

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Case 3:03-cv-01009-SRU Document 67 Filed 12/22/2004 Page 2 of 3 I ’ N
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4. A telephone conference was conducted with the on October 4, 2007 to !
address these issues, however the Court was not able at that time to address all pending g l
motions.
5. The parties agreed to schedule another telephonic conference at a later i
time to address the remaining outstanding issues. The conference still needs to be E il p
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scheduled, however undersigned counsel has contacted the Court for available dates in i
January. 1 I
6. The parties need to address the outstanding motions in order to complete = i
the Joint Trial Brief
7. The plaintiffs need to have the outstanding discovery issues resolved
prior to being able to prepare and file dispositive motions. U
8. The plaintiff would also therefore seek additional time to allow the U i
parties to resolve the outstanding discovery issues prior filing or responding to any -|
dispositive motions in this matter. p
9. Both counsel agree to extension of the -orders as it is in everyone’s best E l
interest to have discovery complete before proceeding to dispositive motions and trial if
necessary. U \
Accordingly, the plaintiffs are seeking an enlargement of time of the scheduling i X
orders to provide to resolve outstanding discovery issues, prepare and file dispositive {
motions and the Joint Trial Brief by February 15, 2005. 2 i
The defendant though Attomey Heather Adams-Beman agrees to this request. R
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Case 3:03-cv-01009-SRU Document 67 Filed 12/22/2004 Page 3 of 3 ` |
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me PLA11~IT11=1=, f
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BY ____ _.»~ ·-`· '``' is'! ;_.·*"`M ____
Cheryl E. ernaiin I
Faver d’ _,/- effeman
2842 gil:}. Dixwell Avenue
_ Ham en, Connecticut 06518
Telephone: 203-288-8266 -
Facsimile: 203-288-4702 \ I
Fed Bar No.:CT 06473 c
CERTIFICATIION
I hereby certify that a copy ofthe foregoing was sent by first class mail, postage prepaid
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this 22"d day of December 2005, to:
Joel J. Rottner, Esq.
Heather Adams—Beman, Esq.
Skelley Rotmer P.C.
PO Box 340890 __ - {
Hartford, CT 06134-0890 __ I
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