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

Case 3:03-cv-01008-SRU

Document 50

Filed 04/05/2005

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UNITED STATES DISTRICT COURT FOR THE DISTRICT OF CONNECTICUT ____________________________________ | HALOX TECHNOLOGIES, INC., | | Plaintiff, | | v. | | DRIPPING WET WATER, INC., | RICHARD L. SAMPSON and | ALLISON H. SAMPSON, | | Defendants. | ____________________________________|

Civil Action No. 3:03 CV 01008 (SRU)

April 5, 2005

JOINT MOTION TO AMEND THE SCHEDULED DEADLINES The parties jointly move this Honorable Court to modify the current scheduling order as follows: (A) On or before April 25, 2005, Defendants shall file and their answer (and any

counterclaims) to the Second Amended Complaint. If Defendants elect to assert the claims in the state court complaint filed in the Texas Action as counterclaims, then that Case (No. 3:04 CV 00752 (SRU)) shall be dismissed; alternatively, the Complaint in that action shall be amended by April 25, 2005. (B) pleadings. (C) (D) On or before August 26, 2005, all motions to join additional parties shall be filed. The party bearing the burden of proof on a particular claim to which an expert On or before May 26, the defendants to such counterclaims shall file responsive

will be called to testify at trial shall designate all such trial experts, exclusive of damages, and

Case 3:03-cv-01008-SRU

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provide opposing counsel with reports from retained experts pursuant to Fed.R.Civ.P 26(a)(2) by January 23, 2006. (E) A damages analysis will be provided by any party who has a claim or

counterclaim for damages by March 2, 2006. (F) (G) Expert rebuttal reports shall be provided to opposing counsel March 17, 2006. All discovery, including depositions of expert witnesses pursuant to Fed. R. Civ.

P. 26(b)(4), will be completed by May 8, 2006. (H) (I) Dispositive motions will be filed on or before June 22, 2006. The joint trial memorandum required by the standing order on trial memoranda in

civil cases will be filed within thirty days of the disposition of the dispositive motions. For Plaintiff, For Defendants,

/s/ Michael J. Rye (ct 18354) Charles F. O'Brien (ct 22074) CANTOR COLBURN LLP 55 Griffin Road South Bloomfield, Connecticut 06002 Telephone: (860) 286-2929 Facsimile: (860) 286-0115 Email: [email protected] Date: 4/5/05 ______

/s/ Edward R. Scofield (ct 00455) Zeldes, Needle & Cooper 1000 Lafayette Boulevard Post Office Box 1740 Bridgeport, Connecticut 06601 Telephone: (203) 333-9441 Facsimile: (203) 333-1489 email: [email protected] Date: __4/5/05_________

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Case 3:03-cv-01008-SRU

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CERTIFICATION

This is to certify that a copy of the foregoing has been sent via U.S. First Class Mail, postage prepaid, on this date, to:

Michael J. Rye, Esq. Charles F. O'Brien, Esq. Cantor & Colburn LLP 55 Griffin Road South Bloomfield, CT 06002 Dated at Bridgeport, Connecticut on this 5th day of April, 2005.

____________________/s/ Edward R. Scofield

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