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

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” ase 3:03-cv-O1009(iiRU Document 24 Filed O1/16/2004 Page 1 of 3 N
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UNITED STATES DISTRICT COUR"§R [5g;?i:_>?·€i;—»il? `iI5*° ‘·
DISTRICT OF CONNECTICUT `" { A "” ’
JOSEPH ATTIAS & HAIM ATTIAS z CIVIL NO. 3:03 CV 01009 (SRU) j
Plaintiffs :
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PATRONS MUTUAL INSURANCE 1
COMPANY OF CONNECTICUT :
Defendant : January 15, 2004
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MOTION FOR ENLARGEMENT OF TIME FOR SCHEDULING ORDERS AND
TO CONTINUE JURY SELECTION
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 and the commencement of Jury Selection in the above matter for
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the following reasons: I
l. The scheduling orders were entered into between the parties and counsel i
on or about August 7, 2003 when the defendant was represented by
4 Attorney Stuart G. Blackburn by way of the Planning Meeting Report l
dated August 7, 2003. Under said agreement/orders discovery was to be j
commenced by August l, 2003 and completed by 2/28/04, dispositive
_ motions to be filed by 3/30/04, the Joint Trial Memorandum to be filed
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by 3/30/04 and the case be ready for trial by April 2004.
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. ·- Cage 3§O3-CV-O`lOO?i§qU Document 24 Filed O1/1€z,?j>O4 Page 2 of 3 I
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2. The plaintiff in accordance with the scheduling order forwarded the
defendants a notice of deposition dated August 8, 2003 scheduling the I
defendant’s deposition for September 8, and thereafter noticed the
deposition of a witness Margaret Ralphs for November 25, 2003 . I
3. On or about September 10, 2003 Attorney Joel Rottner appeared on I
behalf of the defendant as new counsel. As a result the scheduled I
deposition ofthe defendant was continued. Additionally the deposition
of Margaret Ralphs was unable to be obtained until January 9, 2004 due I
to personal reasons of the witness.
4. Accordingly the progression of discovery in this case has been delayed
without fault of the plaintiff.
5. The plaintiff has a number of additional fact witnesses to depose as yet
and the defendant has also indicated the need to obtain depositions of at I
least five (5) persons including the plaintiffs. I
l 6. Additionally, the parties are commencing settlement discussions.
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Accordingly, the plaintiffs are seeking an enlargement of time of the scheduling
orders as follows:
l. Discovery, including all depositions to be completed by 3/3l/04. l
2. A damage analysis completed by 4/30/04.
3. Dispositive motion filed by 4/30/04.
4. Joint Trial Memorandum filed by 4/30/04.
5. Ready for Trial 5/l/04.
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W ` ase 3:03-cv-O1OOQÂ¥SBU Document 24 Filed O1/1E?/2004 Page 3 of 3
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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. I
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This is the first request for enlargement filed by the plaintiffs in this matter. I
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THE PLAINTIFF, I
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BY ll “_____,___,,.... _____,....--—·*·"‘; dv-__-_"____ ..,.. .~ »--·· I
I r‘l‘ Ch"‘>’1E~<’·G§?~* an *
Law O, c _, I Cheryl E. Heffernan
2842 }d‘l)ixwell Avenue l
Ham en, Connecticut 06518 I
Telephone: 203—288—8266
Facsimile: 203-288-4702 I
Fed Bar No.:CT 06473 I
CERTIFICATION I

I hereby certify that a copy ofthe foregoing was sent by first class mail, postage prepaid
this l5'h day of January 2004, to: I
Joel J. Rottner, Esq.
Skelley Rottner P.C. I
PO Box 340890 ?_,/ n
Hartford, CT 06134-0890 _I,_ ~··‘ " __,,j·jQg¢~“' ____7 _ __I_, _ .
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Chery ;@,,He‘ffer1ian I
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