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

Case 3:03-cv-01003-AWT

Document 47

Filed 03/31/2005

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)

MARCH 31, 2005

MOTION FOR EXTENSION OF TIME The defendant, C&S Wholesale Grocers, Inc. ("C&S") moves for an extension of time of six weeks, up to and including May 10, 2005, for the parties to complete discovery. C&S also requests an extension of time of six weeks, up to and including July 11, 2005, in which to file any dispositive motions, and an extension of time of six weeks, up to and including July 11, 2005, to file the joint trial memorandum. This is C&S's third request for an extension of time of the discovery deadlines, and its fourth request for an extension of time with respect to the dispositive motion and joint trial memorandum deadlines. C&S requires the additional time to conduct discovery related to several discrete issues, including items learned during the continued deposition of Mr. Bucknor on March 28, 2005. Kenneth Friedman, counsel for Mr. Bucknor, has no objection to an extension of the discovery deadline as set forth above. Mr. Friedman also has no objection to a corresponding extension of the dispositive motion and joint trial memorandum deadlines.

Case 3:03-cv-01003-AWT

Document 47

Filed 03/31/2005

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DEFENDANT C&S WHOLESALE GROCERS, INC.

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] Its Attorneys

-2-

Case 3:03-cv-01003-AWT

Document 47

Filed 03/31/2005

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CERTIFICATE OF SERVICE I hereby certify that a copy of the foregoing Motion for Extension of Time was mailed first class, postage prepaid, on this 31st day of March, 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