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

Case 3:03-cv-01008-SRU Document 70 Filed 01/18/2006 Page 1 of 3
UNITED STATES DISTRICT COURT
E OR THE DISTRICT OP CONNECTICUT
I
HALOX TECHNOLOGIES, INC., I
I
Plaintifi |
Counterclaim Defendant I
v. I Civil Action No. 3:03CV0l008 (SRU)
I
DRIPPING WET WATER, INC., I
RICHARD L. SAMPSON and I
ALLISON H. SAMPSON, I
I
Defendants. I
Counterclaim Plaintiffs I
I
I
PULSAFEEDER, INC. and IDEX CORP. I
I
Additional Counterclaim I
Defendants I
I
JOINT MOTION TO AMEND THE SCHEDULED DEADLINES
The parties jointly move this Honorable Court to modify the Scheduling Order entered by
this Court on April 8, 2005 as follows:
l. 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, and
dispositive motions are to be tiled on or before June 22, 2006.
2. Pursuant to the current Scheduling Order, the party bearing the burden of proof on a
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 January 23, 2006. The parties hereby move this Honorable

Case 3:03-cv—01008-SRU Document 70 Filed 01/18/2006 Page 2 of 3
Court to change the date upon which such expert reports are due from January 23, 2006 to March
24, 2006.
3. 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 2, 2006. The parties hereby move
this Honorable Court to change the date upon which such damages analysis is due from March 2,
2006 to March 24, 2006.
4. Pursuant to the current Scheduling Order, expert rebuttal reports are to be provided to
opposing counsel by March 17, 2006. The parties hereby move this Honorable Court to change
the date upon which such expert rebuttal reports are due from March 17, 2006 to April 7, 2006.
5. The requested revised dates will not extend or otherwise affect either the date upon
which all discovery is set to be completed under the current Scheduling Order, or the date upon
which dispositive motions are to be filed under the current Scheduling Order.
For Pfahvf f an For Defendants and
Counters aim D fendants, Counterclaim Plaintiffs,
é
at · . i (J
Charl . O ` (ct 22074) Frank Prisenda, Jr.
Michael J. Rye (ct 18354) Admitted Pro Hac Vice
CANTOR COLBURN LLP Frisenda, Quinton & Nicholson
55 Griffin Road South 11601 Wilshire Blvd., Suite 500
Bloomfield, Connecticut 06002 Los Angeles, California 90025
· Telephone: (860) 286-2929 Telephone: (702) 792-3910
Facsimile: (860) 286-0115 Facsimile: (702) 792-3604
Date: li lnllgfy Date: Ob
2

Case 3:03-cv—01008-SRU Document 70 Filed 01/18/2006 Page 3 of 3
CERTIFICATE OF SERVICE
lhereby certify that a true and accurate copy of the Joint Motion to Ainencluétxhe Scheduled
Deadlines was served via facsimile and regular mail, postage prepaid, on this {7 day of
January, 2006 upon:
Edward R. Scofield, Esq.
Zeldes, Needle & Cooper, P.C.
1000 Lafayette Blvd., Suite 500
Bridgeport, Comiecticut 06604
Facsimile: (203) 333-1489
Frank Frisenda, Jr.
Frisenda, Quinton & Nicholson
l160l Wilshire Blvd., Suite 500;/
Los Angeles, California 90025 j \
Facsimile: (702) 792-3604 A t
l l
By:
Charles . O’BI`l€I1
3