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

Case 3:03-cv-01003-AWT

Document 45

Filed 02/08/2005

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)

FEBRUARY 8, 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 March 29, 2005, for the parties to complete discovery. C&S also requests an extension of time of six weeks, up to and including May 30, 2005, in which to file any dispositive motions, and an extension of time of six weeks, up to and including June 30, 2005, to file the joint trial memorandum. This is C&S's second request for an extension of time of the discovery deadlines, and its third request for an extension of time with respect to the dispositive motion and joint trial memorandum deadlines. C&S requires the additional time for the sole purpose of completing the deposition of Mr. Bucknor. The parties have been unable to schedule Mr. Bucknor's deposition prior to the February 15 discovery deadline, but have discussed completing Mr. Bucknor's deposition during the last two weeks of February.

Case 3:03-cv-01003-AWT

Document 45

Filed 02/08/2005

Page 2 of 3

Kenneth Friedman, counsel for Mr. Bucknor, consents to an extension of the discovery deadline as set forth above. Mr. Friedman also consents to a corresponding extension of the dispositive motion and joint trial memorandum deadlines. 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 45

Filed 02/08/2005

Page 3 of 3

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 8th day of February, 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