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

Case 3:03-cv-01009-SRU

Document 64

Filed 10/20/2004

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UNITED STATES DISTRICT COURT DISTRICT OF CONNECTICUT JOSEPH ATTIAS & HAIM ATTIAS VS. PATRONS MUTUAL INSURANCE COMPANY OF CONNECTICUT : : : : : : CIVIL ACTION NO. 3:03 CV 01009 (SRU)

OCTOBER 18, 2004

DEFENDANT'S MOTION FOR ENLARGEMENT OF TIME FOR SCHEDULING ORDERS The defendant, Patrons Mutual Insurance Company, hereby requests an enlargement of time with respect to the scheduling orders requested by the plaintiff and entered into by the Court on July 14, 2004 for an additional forty-five (45) days beyond the time to allow for the filing of dispositive motions for the following reasons: 1. The parties had previously agreed to the plaintiffs' Motion for Enlargement of

Time, dated July 14, 2004. 2. Said motion requested an enlargement of time of the scheduling orders in Nos.

1 through 4 as follows: 1. 2. 3. 4. Discovery, including all depositions to be completed by 8/31/04. A damage analysis completed by 9/30/04 Dispositive motion filed by 10/31/04 Joint Trial Memorandum filed by 10/31/04.

SR/225353/bsw

Case 3:03-cv-01009-SRU

Document 64

Filed 10/20/2004

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3. issues. 4.

The parties have filed several motions with respect to unresolved discovery

The defendant is in the process of compiling and preparing certain discovery

materials in accordance with the Court's ruling of October 7, 2004. 5. The Court agreed during the October 7, 2004 teleconference to conduct a

further status conference regarding the remaining discovery disputes; to date, said conference is unscheduled. 6. The parties need to resolve the outstanding discovery issues in order to properly

prepare and complete the Joint Trial Brief. 7. The defendant would also therefore seek additional time to allow the parties to

resolve the outstanding discovery issues prior to the filing of any dispositive motions in the above-referenced matter. 8. Undersigned counsel contacted counsel for the plaintiffs regarding said request

and was advised by Attorney Heffernan's assistant that the plaintiffs have no objection to the present request. WHEREFORE, the defendant requests an extension of time for an additional fortyfive (45) days and seeks an enlargement of time for the scheduling orders.

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Case 3:03-cv-01009-SRU

Document 64

Filed 10/20/2004

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DEFENDANT, PATRONS MUTUAL INSURANCE COMPANY

By

\S\ Heather J. Adams-Beman Skelley Rottner P.C. P.O. Box 340890 Hartford, CT 06134-0890 Tel. (860) 561-7077 Fax (860) 561-7088 Federal Bar No. ct24091

CERTIFICATION I hereby certify that a copy of the above was mailed via U.S. Mail, postage prepaid, on October 18, 2004, to the following counsel of record: Attorney Cheryl E. Heffernan Farver & Heffernan 2842 Old Dixwell Avenue Hamden, CT 06518 Tel. (203) 288-8266

\S\ Heather J. Adams-Beman

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