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

Case 3:03-cv-01003-AWT

Document 38

Filed 11/10/2004

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)

November 9, 2004

JOINT MOTION FOR EXTENSION OF TIME The parties jointly move for an extension of time of two (2) months, up to and including February 15, 2005, in which to complete discovery and file any dispositive motions. Similarly, the parties move for an extension of time of two (2) months, up to and including March 18, 2005, to file their joint trial memorandum, if no dispositive motions are filed. This is the parties' first request for an extension of time with respect to the discovery deadline, the filing of dispositive motions, and the filing of the joint trial memorandum. This request is made because of the need to obtain additional third party documents, and thereafter complete depositions. This Motion is filed as a joint motion with the express consent of counsel for the plaintiff.

Case 3:03-cv-01003-AWT

Document 38

Filed 11/10/2004

Page 2 of 3

DEFENDANT ­ C&S WHOLESALE GROCERS, INC.

By/s/ Scott E. Schaffer Scott E. Schaffer - ct25325 Murtha Cullina LLP CityPlace I ­ 185 Asylum Street Hartford, CT 06103 Its Attorneys Tel. No.: 860-240-6000 Fax No.: 860-240-6150 [email protected]

Case 3:03-cv-01003-AWT

Document 38

Filed 11/10/2004

Page 3 of 3

CERTIFICATE OF SERVICE I hereby certify that a copy of the foregoing was mailed first-class, postage prepaid, on this 9th day of November 2004, to: Kenneth I. Friedman Law Offices of Kenneth I. Friedman 2389 Main Street Glastonbury, CT 06033

/s/ Scott E. Schaffer Scott E. Schaffer - ct25325

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