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

Case 3:03-cv-01003-AWT

Document 49

Filed 06/10/2005

Page 1 of 3

UNITED STATES DISTRICT COURT DISTRICT OF CONNECTICUT VALENTINE BUCKNOR, Plaintiff, v. C&S WHOLESALE GROCERS, INC., Defendant. : : : : : : : : :

CIVIL ACTION NO. 3:03-CV-01003 (AWT)

JUNE 10, 2005

JOINT MOTION FOR EXTENSION OF DEADLINES The parties jointly move for an extension of time up to and including July 1, 2005, for the parties to complete discovery. The parties have been focusing on settlement during the past several weeks, and have agreed to schedule a final deposition during the month of June. The parties also jointly request an extension of time up to and including September 1, 2005, in which to file any dispositive motions, and an extension of time, up to and including September 30, 2005, to file the joint trial memorandum. Defendant has previously requested to extend the discovery deadline on three occasions, and the joint trial memorandum and dispositive motion deadline on four occasions, but this is the parties' first joint motion for an extension of the applicable deadlines.

Case 3:03-cv-01003-AWT

Document 49

Filed 06/10/2005

Page 2 of 3

DEFENDANT C&S WHOLESALE GROCERS, INC.

PLAINTIFF ­ VALENTINE BUCKNOR

By ____/s/ Derek T. Werner_____________ Lissa J. Paris ­ ct04251 Derek T. Werner ­ ct23419 Murtha Cullina LLP CityPlace I ­ 185 Asylum Street Hartford, Connecticut 06103-3469 Telephone: (860) 240-6000 Facsimile: (860) 240-6150 Email: [email protected]
[email protected]

By ______/s/ Kenneth I. Friedman______ Kenneth I. Friedman ­ ct03344 Law Offices of Kenneth I. Friedman 2389 Main Street Glastonbury, Connecticut 06033 Telephone: (860) 659-6557 Facsimile: (860) 659-1625 Email: [email protected] His Attorney

Its Attorneys

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Case 3:03-cv-01003-AWT

Document 49

Filed 06/10/2005

Page 3 of 3

CERTIFICATE OF SERVICE I hereby certify that a copy of the foregoing Joint Motion for Extension of Deadlines was mailed first class, postage prepaid, on this 10th day of June, 2005 to: Kenneth I. Friedman, Esq. Law Offices of Kenneth I. Friedman 2389 Main Street Glastonbury, Connecticut 06033

/s/ Derek T. Werner Derek T. Werner ­ct23419