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

Case 3:03-cv-01008-SRU Document 73 Filed 03/16/2006 Page 1 of 4 j
IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF CONNECTICUT
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HALOX TECHNOLOGIES, INC., I
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Plaintiff] I
CounterclaimpDef`endant I
v. I I Civil Action No. 3:03CV0l008 (SRU)
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DRIPPING WET WATER, INC., I
RICHARD L. SAI\/IPSON and I
ALLISON H. SAMPSON, I
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· Defendants. I
Counterclaim Plaintiffs I
————-——————————-———————---——-—-I
PULSAFEEDER, INC. and IDEX CORP. I
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Additional Counterclairn I
Defendants I
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JOINT MOTION TO AMEND THE SCHEDULING ORDER
The parties jointly move this Court to modify the current scheduling order. As grounds
therefore, the parties state that settlement discussions have recently taken place to resolve this
matter. Specifically, the parties recently discussed a resolution of this matter that led to
Defendants (also Counterclairn Plaintiffs) extending a written proposal to settle this matter dated
March 2, 2006. Plaintiff and Counterclaim Defendants responded with a written counterproposal
dated March 10, 2006. The parties are continuing to discuss the resolution of this matter. As
the parties are currently making good faith efforts settle this matter, the parties hereby jointly .
move this Court to amend the current scheduling order by extended the deadlines by forty—iive
(45) days as follows:

Case 3:03-cv-01008-SRU Document 73 Filed 03/16/2006 Page 2 of 4
1. Pursuant to the current Scheduling Order, the party bearing the burden of proof on a P
particular claim to which an expert will be called to testify at trial shall designate all such trial
experts, exclusive of damages, and provide opposing counsel with reports from retained experts
pursuant to Fed.R.Civ.P 26(a)(2) by March 24, 2006. The parties hereby move this Honorable
Court to change the date upon which such expert reports are due to May 9, 2006.
2. Pursuant to the current Scheduling Order, damages analysis is to be provided by any
party who has a claim or counterclaim for damages by March 24, 2006. The parties hereby
move this Honorable Court to change the date upon which such damages analysis is due to May
9, 2006.
3. Pursuant to the current Scheduling Order, expert rebuttal reports are to be provided to
opposing counsel by April 7, 2006. The parties hereby move this Honorable Court to change the
date upon which such expert rebuttal reports are due to May 23, 2006.
4. Pursuant to the current Scheduling Order, all discovery, including depositions of
expert witnesses pursuant to Fed. R. Civ. P. 26(b)(4), is to be completed by May 8, 2006. The
parties hereby move this Honorable Court to change the date upon which such expert rebuttal
‘ reports are due to June 22, 2006. 1
5. Pursuant to the current Scheduling Order, dispositive motions are to be tiled on or
before June 22, 2006. The parties hereby move this Honorable Court to change the date upon
which such expert rebuttal reports are due to August 6, 2006.
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Case 3:03-cv-01008-SRU Document 73 Filed 03/16/2006 Page 3 of 4 (
Fo éla . d For Defendants and 1
C • 1 II efendants, Counterclaim Plaintiffs,
L ( QQ. i
Ch s F. O’ Brien (ct 22074) Frank Frisenda, Jr.
Michael J. Rye (ct 18354) Admitted Pro Hac Vice
CANTOR COLBURN LLP Frisenda, Quinton & Nicholson
55 Grifiin Road South 11601 Wilshire Blvd., Suite 500
Bloomfield, Connecticut 06002 Los Angeles, California 90025
Telephone: (860) 286-2929 Telephone: (702) 792-3910 f
Facsimile: (860) 286-0115 Facsimile: (702) 792-3604
Date: Date:
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Case 3:03-cv—01008-SRU Document 73 Filed 03/16/2006 Page 4 of 4 {
CERTIFICATE OF SERVICE
I hereby certify that a true and accurate copy of the Joint Motion to Amend the Scheduled
Deadlines was served via facsimile and regular mail, postage prepaid, on this 15th day of March,
2006 upon:
Edward R. Scofield, Esq.
Zeldes, Needle & Cooper, P.C.
1000 Lafayette Blvd., Suite 500
Bridgeport, Connecticut 06604
Facsimile: (203) 333-1489
Frank Frisenda, Jr.
Frisenda, Quinton & Nicholson
11601 Wilshire Blvd., Suite 5
Los Angeles, California 900 5
Facsimile: (702) 792-360
By:
Charles F. O’Brien
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