.... `... ..,.2 ,...D2_. nsw ...TL... _.wm“..“._-._.-;...-.—m..u.t..,.T..*....w_.;..._1.__,w_ · I
Case 3:03-cv-01009-SRU Document 67 Filed 12/22/2004 Page 1 of 3 I
· . I
20011 BEC 2 2 P l2= 33
I
II" .sIRlcI cows? J
UNITED STATES DISTRICT C(DiHgIll§§—â€[]§{'I`, IIIIIEII
ggsrmcr or CONNECTICUT I
I I
JOSEPH Arms Ss HAIM ATTIAS z CIVIL N0. 303 cv 01009 (SRU) “ I
Plaintiffs : I I I
I
PATRONS MUTUAL INSURANCE I I I I
COMPANY or CONNECTICUT I I I
Defendant 2 DECEMBER 21, 2004 I
I
PLAINTIFFEP MOTION Fon ENLARGEMENT
on TIME Fon SCHEDULING oimmzs
I
The Plaintiffs Joseph & Haim Attias, hereby request through their counsel for an ‘
I
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
Q I
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
,· -|-
....
pqqqn pqqn ; I qq I qq I qq I qq I qq I qq gg qq I I ~ I Srre I Srre r * Srre ’
....
Case 3:03-cv-01009-SRU Document 67 Filed 12/22/2004 Page 2 of 3 I ’ N
. t
l
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
l r .
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
r r
" `I ‘I
Ii
Case 3:03-cv-01009-SRU Document 67 Filed 12/22/2004 Page 3 of 3 ` |
I I
I E
I I \
me PLA11~IT11=1=, f
I - I
BN//m~ `NIMMM dw _J,.··‘i"-_l:L_;;—,;1?`°’ I
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
r I
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
J_,,·;·N M.;Mw__ ____ k_,,,;t_ ____,.·—N‘·- "Iw“r'_,_,,, ...... I
df;.y_'_,..»··*"'°`w I
Cheryl E,E·effeman E IL
I I ‘
I I I
I I
'I
I
I I
I
i | l
I I I
I I
3 I I
`I Z
I
,m_______.____,_____,_ __.,,_...___,.___.._.,._.-.....i._.._-__-... .. r I