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

v `” i 1 Case 3:03-cv-O100§;$RU Document 33 Filed O3/18[%OO4 Page 1 of 3 {
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UNITED STATES DISTRICT COURT BmL?il.$éTRlCT COURT I
DI I PUR IZ CUNPI
STRICT OF CONNECTICUT · {
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JOSEPH ATTIAS & HAIM ATTIAS ; CIVIL NO. 3:03 CV 01009 (SRU) i
Plaintiffs : {
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PATRONS MUTUAL INSURANCE : {
COMPANY OF CONNECTICUT : {
Defendant : MARCH 16,2004 {
MOTION FOR ENLARGEMENT OF TIME FOR SCHEDULING ORDERS
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The Plaintiffs Joseph & Haim Attias, hereby request through their counsel for an
enlargement of time in regards to the scheduling orders entered into by the parties on or
about August 7, 2003 for the following reasons:
1. The scheduling orders were entered into between the parties and counsel
on or about August 7, 2003 when the defendant was represented by |
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Attorney Stuart G. Blackburn by way of the Planning Meeting Report {
dated August 7, 2003. Under said agreement/orders discovery was to be {
commenced by August 1, 2003 and completed by 2/28/04, dispositive
motions to be filed by 3/30/04, the Joint Trial Memorandum to be filed Y
by 3f30/04 and the case be ready for trial by April 2004.
2. By way of a motion for enlargement dated January 19, 2004 the
plaintiffs’ with the agreement of the defendant requested an enlargement

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l I 3 Case 3:03-cv-O10(Q%RU Document 33 Filed O3/138/$004 Page 2 of 3 3
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ofthe scheduling orders. The Court granted the enlargement until
March 31, 2004 for discovery and May 31 for Dispositive motions and
Joint Trial Memorandum.
3. The discovery phase of this case has taken longer then originally 3
anticipated by the parties, in part due to scheduling conflicts of counsel. 3
4. The anticipate that discovery can be completed by the end of the month
of April. 3
Accordingly, the plaintiffs are seeking an enlargement of time of the scheduling 3
orders as follows: 3
l. Discovery, including all depositions to be completed by 4/30/04. 3
2. A damage analysis completed by 5/31/04.
3. Dispositive motion tiled by 5/31/04. l
4. Joint Trial Memorandum filed by 6/30/04 or 30 days after a decision on
any and all dispositive motins, whichever comes later.
5. Ready for Trial 6/30/04.
The defendant though its counsel, Attorney Joel Rottner, has no objection to the
granting of this motion and the requested changes of the scheduling order. 3
This is the second request for enlargement filed by the plaintiffs in this matter.
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Case 3:03-cv-O1OOQ)rgRU Document 33 Filed O3/1(8f$OO4 Page 3 of 3 {
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THE PLAINTIFF,
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BY M , ·a~’‘` _, I
Cheryl E. Hef an
Faver & I·Ief {nan
2842 Old Di ell Avenue
Hamden, Connecticut 06518 l
Telephone; 203—288—8266 I
Facsimile: 203-288-4702 l
Fed Bar No.:CT 06473
CERTIFICATION
. I hereby certify that a copy of the foregoing was sent by first class mail, postage prepaid
this l6"‘ day of March 2004, to:
Joel J. Rottner, Esq.
Skelley Rottner P.C.
PO Box 340890
Hartford, cr 06134-0890
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Cheryl E. I-I ` e i
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