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

Case 3:03-cv-00998-JGM

Document 36

Filed 10/08/2004

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UNITED STATES DISTRICT COURT FOR THE DISTRICT OF CONNECTICUT(NEW HAVEN)

____________________________________________ ) ) ) V. ) ) THAMES VALLEY WATER BOTTLING CO., INC. ) ________________________________________________) SANTIAGO E. CARTAGENA CIVIL ACTION NO. 3:03 CV 99*(JGM)

OCTOBER 6, 2004

JOINT MOTION FOR EXTENSION OF TIME Pursuant to Local Rule 7(b) and (d), counsel for SANTIAGO E. CARTAGENA, the Plaintiff in the above-captioned matter, and THAMES VALLEY WATER BOTTLING COMPANY, INC., the Defendant in the above-captioned matter, hereby move the Court for an extension of time to file their Joint Trial Memorandum, which is presently due on October 15, 2004. The parties request an extension of time to November 15, 2004. This is the first request for an extension of time with respect to the Joint Trial Memorandum. This request is made for the following reasons: (1) As to the Plaintiff: lack of response from the Plaintiff to his undersigned counsel, and

Case 3:03-cv-00998-JGM

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the trial schedule of the undersigned counsel for the Plaintiff in this and the next weeks; (2) As to the Defendant: outstanding discovery is due from the Plaintiff by October 18, 2004 [per Order, Pesta, J.], in the absence of which the Defendant is unable to complete its portion of the Joint Trial Memorandum, or, failing production of the outstanding discovery by the Plaintiff, to prepare an appropriate motion for dismissal or for judgment of default pursuant to Fed. Rule Civ. Proc.§37(b)(2)(C), after October 18, 2004. WHEREFORE, the parties move that the time for filing of their Joint Trial Memorandum be extended to November 15, 2004. THE PLAINTIFF THE DEFENDANT

By ___________________________ Thomas W. Bucci for Willinger, Willinger & Bucci, P.C. 855 Main Street Bridgeport, CT 06604 Phone: (203) 366-3939 Fax: (203) 337-4588 Fed. Bar No. ct07805

By _____________________________ Richard J. Pascal for O'Brien, Shafner, Stuart, Kelly & Morris, P. C. 138 Main Street P. O. Box 310 Norwich, CT 06360 Phone: (860) 889-3855 Fax: (860) 886-6352 Federal Bar No. ct 03151 CERTIFICATION OF SERVICE

I hereby certify that a copy of the foregoing has been mailed, postage prepaid, on this 6th day of October, 2004, to the following:

Case 3:03-cv-00998-JGM

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Thomas W. Bucci, Esq. Wilinger, Willinger & Bucci, P.C. 855 Main Street Bridgeport, CT 06604 By_________________________________ Richard J. Pascal for O'Brien, Shafner, Stuart, Kelly & Morris, P. C. 138 Main Street P. O. Box 310 Norwich, CT 06360 Phone: (860) 889-3855 Fax: (860) 886-6352 Federal Bar No. ct 03151

Case 3:03-cv-00998-JGM

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Filed 10/08/2004

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MotionExtensionTime