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

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N · ase 3:03-cv-01009-SRU Document 39 Filed O4/22/2004 .= ge 1 of 3 j
FILED
N ZIIBII APR 22 P Ii 0| ,
N U.S. DISTRICT CDU! T l i
N ‘ . I _, _ BRIDGEPORT, CUM i
N UNITED STATES DISTRICT COURT ’ E
DISTRICT OF CONNECTICUT · i
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JOSEPH ATTIAS & HAIM ATTIAS : CIVIL NO. 3:0 CV 01009 (SRU) N
Plaintiffs : {
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PATRONS MUTUAL INSURANCE : N N
COMPANY OF CONNECTICUT : N
Defendant : APRIL 21, 200 i Q
MOTION FOR ENLARGEMENT OF TIME FOR SCHEDUL G ORDERS N
The Plaintiffs Joseph & Haim Attias, hereby request through th ir counsel for an N
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enlargement of time in regards to the scheduling orders entered into by he parties on or j ;
about August 7, 2003 for the following reasons: I
1. The scheduling orders were entered into between the p I ties and counsel N
on or about August 7, 2003 when the defendant was re N esented by ·
Attorney Stuart G. Blackburn by way ofthe Planning eeting Report N
dated August 7, 2003. Under said agreement/orders di covery was to be ;
commenced by August l, 2003 and completed by 2/28/ 4, dispositive
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motions to be filed by 3/30/04, the Joint Trial Memoran um to be filed I `
by 3/30/O4 and the case be ready for trial by April 2004 E N
2. By way of a motion for enlargement dated January 19, 004 the 2
p1aintiffs’ with the agreement of the defendant requests: an enlargement
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I I ase 3:03-cv-01009-SRU Document 39 Filed O4/22/2004 P ge 2 of 3 .
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of the scheduling orders. The Court granted the eniar ement until I
March 31, 2004 for discovery and May 3l for Disposit ve motions and E I
Joint Trial Memorandum. I i
3. By way of motion dated March 16, 2004 the plaintiffs ought a further I
enlargement of the scheduling orders which was granted by the Court I
4. The current orders ends the discovery phase of this cas on April 31, I
2004.
5. A discovery dispute has recently occurred resulting in is e filing of a I
Motion for Order of Compliance dated April 19, 2004 y the plaintiffs.
6. Due to this dispute discovery cannot be completed by pril 31, 2004. !
Accordingly, the plaintiffs are seeking an enlargement of time f the scheduling
orders to provide that discovery is to be completed within 30 days of co pliance by the {
defendant of disputed discovery requests or the court’s order on the plai tiffs’ Motion for Z
Order of Compliance, whichever occurs later, with the deadlines for theldamage analysis, I I
dispositive motions and Joint Trial memorandum continued proportion l ly I I
The defendant though a member of its counsel’s office, Attorne Miller, has no I
objection to the granting of this motion and the requested changes of th scheduling ;
order. l
This is the third request for enlargement filed by the plaintiffs iI this matter.
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3 D ase 3:03-cv-01009-SRU Document 39 Filed O4/22/2004 P3ge 3 of 3 Z
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THE PLAINTIFF, -
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BY ,33»— ___,_-4;. -·‘’ ky 3 __
Ch iyiigggf 3333 3 -
1*%*1* Ri Heffernan I " 3
2 2 Old Dixwell Aven 3e , 3
Hamden, Connecticut Od 18 3,
Telephone: 203-288-826
Facsimile: 203-288-47023
Fed Bar N0. :CT 06473
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CERTIFICATION 3
I hereby certify that a copy ofthe foregoing was sent by first class ma 1, postage prepaid _ 3 3
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this 21“ day of April 2004, to; j 3 3
Joel J. Rottner, Esq. 3
Heather Adams-Beman, Esq. 3 3
Skeliey Rottner P.C.
PO Box 340890 . i 3 I
Hartford, CT 06134-0890 / ` 3 3
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