Free Response - District Court of Connecticut - Connecticut

Case 3:03-cv-00986-JCH

Document 37

Filed 03/26/2004

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UNITED STATES DISTRICT COURT DISTRICT OF CONNECTICUT

SUSAN E. WOOD, Plaintiff, - against SEMPRA ENERGY TRADING CORPORATION, Defendant.

CIVIL ACTION NO. 3:03-CV-986 (JCH)

March 25, 2004

OBJECTION TO DEFENDANT'S MOTION FOR MODIFICATION OF DISPOSITIVE MOTION DEADLINE

Plaintiff, Susan E. Wood ("Plaintiff"), hereby objects to the Defendant's Motion for Modification of Dispositive Motion Deadline, dated March 23, 2004 ("Motion for Extension of Time"). Support for Defendant's Motion for Extension of Time is based upon the recent modifications to the discovery deadline. The discovery deadline, however, was extended at the request of the Defendant earlier this year. In seeking the extension to the original discovery deadline, Defendant reported to the Court that there would not be a need to extend the dispositive motion deadline and the trial would not be delayed. Given the fact that the Scheduling Order ties the date for trial into the Court's decision on dispositive motions, the extension sought by the Defendant will necessarily delay the trial date. Further, Plaintiff asserts that the only open discovery matters are the depositions that Plaintiff needs to complete of the Defendant's employees. Those depositions are not necessary for any submission contemplated by the

Case 3:03-cv-00986-JCH

Document 37

Filed 03/26/2004

Page 2 of 3

Defendant inasmuch as Defendant is in control of each of the witnesses that Plaintiff plans to depose by the discovery cutoff and, therefore, any factual assertions that Defendant wishes to make in any future dispositive motion can be supported by affidavit. By reason of the foregoing, Plaintiff objects to Defendant's Motion for Extension of Time.

PLAINTIFF, SUSAN E. WOOD

By:_________________________________ Brendan J. O'Rourke, Esq. (ct00522) Jeffrey M. McCormick, Esq. (ct21185) O'ROURKE & ASSOCIATES LLC 27 Pine Street New Canaan, CT 06840 Telephone: (203) 966-6664 Facsimile: (203) 966-5710 [email protected]

Brendan O'Rourke

Digitally signed by Brendan O'Rourke DN: CN = Brendan O'Rourke, C = US, O = O'Rourke Date: 2004.03.25 11:07:23 -05'00'

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Case 3:03-cv-00986-JCH

Document 37

Filed 03/26/2004

Page 3 of 3

CERTIFICATE OF SERVICE This is to certify that on this 25th day of March, 2004, a copy of the foregoing Objection to Defendant's Motion for Modification of Dispositive Motion Deadline was forwarded via regular mail to counsel of record at the following address:

Peter M. Schultz, Esq. Paul, Hastings, Janofsky & Walker, LLP 1055 Washington Blvd. Stamford, CT 06901

DN: CN = Brendan O'Rourke, C = Brendan US, O = O'Rourke Date: 2004.03.25 11:07:46 -05'00' O'Rourke ________________________

Digitally signed by Brendan O'Rourke

Brendan J. O'Rourke, Esq.

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