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

Case 3:03-cv-00990-AWT

Document 17

Filed 02/23/2004

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UNITED STATES DISTRICT COURT DISTRICT OF CONNECTICUT ALEXANDER GRAHAM and JOSE CUEVAS Plaintiffs VS. FIRELINE, INC. Defendant : : : : : : : : : : CIVIL ACTION NO. 303CV990(AWT)

FEBRUARY 19, 2004

JOINT MOTION TO AMENDED CASE MANAGEMENT PLAN The Parties herein hereby move and request that this Honorable Court grant the Parties leave to amend the Case Management Plan Memorialized by Form 26(f), and dated July 7, 2003, by Agreement of such Parties, such that the dates set forth below be modified as follows: E. Discovery: 2. The date for the completion of discovery be modified from June 1, 2004 to September 1, 2004. 5. The date for the completion of all depositions of fact witnesses be modified from June 1, 2004 to September 1, 2004. 7. The date by which Plaintiff must disclose Experts be modified from December 1, 2003 to March 1, 2004. The date by which Depositions of such Experts shall be completed be modified from March 1, 2004 to June 1, 2004.

Case 3:03-cv-00990-AWT

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Filed 02/23/2004

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8. The date by which Defendant must disclose Experts be modified from April 1, 2004 to July 1, 2004. The date by which Depositions of such Experts shall be completed be modified from June 1, 2004 to September 1, 2004. 9. The date by which a Damages Analysis be provided be modified from December 1, 2004 to March 1, 2004. F. Dispositive Motions: The date by which Dispositive motions will be filed be modified from July 1, 2004 to October 1, 2004. G. Joint Trial Memorandum: The Joint Trial Memorandum required by the Standing Order on Trial Memoranda in Civil Cases will be filed within sixty (60) days of the Court's ruling on dispositive motions. The date by which such Memorandum will be filed if no such motions are made, be modified from September 1, 2004 to January 15, 2005. VI. Trial Readiness: The case will be ready for trial within sixty (60) days of the Court's ruling on dispositive motions. The date when this case will be ready for trial, if no such motions are made, be modified from September 15, 2004 to January 30, 2005.

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HFD_97172.1/JHELMKE

Case 3:03-cv-00990-AWT

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Filed 02/23/2004

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THE PLAINTIFF ALEXANDER GRAHAM and JOSE CUEVAS

Dated: February 19, 2004

By ________________________ Thomas A. Virgulto Fed. Bar. No. ct 12058 Mongillo, Insler & Virgulto, P.C. 26 Elm Street New Haven, CT 06510 (203) 787-5805

THE DEFENDANT FIRELINE, INC.

Dated: ____________, 2004

By __________________________ Charles F. Gfeller Fed. Bar No. ct 18119 Edwards & Angell, LLP 90 State House Square Hartford, CT 06103 (860) 525-5065

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Case 3:03-cv-00990-AWT

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Filed 02/23/2004

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ORDER The foregoing Motion having been presented and heard, it is hereby ORDERED: GRANTED / DENIED. BY THE COURT

________________________ Clerk / Judge

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HFD_97172.1/JHELMKE

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Filed 02/23/2004

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CERTIFICATE OF SERVICE This is to certify that a copy of the foregoing Motion to Amend Case Management Plan has been sent, via first class mail, postage prepaid, this 19th day of February, 2004 to: Charles F. Gfeller, Esquire EDWARDS & ANGELL, LLP 90 State House Square Hartford, CT 06103 (860) 525-5065

_______________________________ Thomas A. Virgulto

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