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

Case 3:03-cv-00986-JCH

Document 33

Filed 03/19/2004

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UNITED STATES DISTRICT COURT DISTRICT OF CONNECTICUT

SUSAN E. WOOD, Plaintiff, v. SEMPRA ENERGY TRADING CORPORATION, Defendant.

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

March 19, 2004

MOTION TO MODIFY SCHEDULING ORDER

Plaintiff Susan Wood ("Plaintiff") hereby moves to Modify the Scheduling Order in the above-captioned case. The Scheduling Order in this case currently provides a discovery cutoff date of March 19, 2004. However, based upon the fact that the depositions of a number of employees of Defendant Sempra ("Sempra") had to be rescheduled, which fact has been communicated to the Court, good cause exists to extend the discovery cutoff date to May 3, 2004. This is a request that is reasonably made, as this requested short extension will allow Plaintiff to complete the deposition of six (6) Sempra employees. Further, the Court has been made aware of the need for such modification by Plaintiff's response to Sempra's Motion to postpone the deposition of Sempra's employees due to Defendant's counsel, Peter Schultz's wife's pregnancy, and the ultimate birth of their new child. Further, the depositions of several Sempra employees are currently scheduled to take place in month of April. More particularly, Sempra employees Vin Cookingham, Denise Freda,

Case 3:03-cv-00986-JCH

Document 33

Filed 03/19/2004

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David Messer, Sarathi Roy, Jackie Mitchell, and Brian Cummings are all scheduled to sit for depositions between April 5th and April 14th. Sempra's counsel, Attorney Schultz, consents to the granting of this Motion. This is Plaintiff's first request to modify the Scheduling Order in this case.

Dated: March 19, 2004

Respectfully submitted,

Jeffrey M. McCormick

Digitally signed by Jeffrey M. McCormick DN: CN = Jeffrey M. McCormick, C = US, O = O'Rourke Date: 2004.03.19 12:24:12 05'00'

By: ________________________________ Brendan J. O'Rourke, Esq. (ct 00522) Jeffrey M. McCormick, Esq. (ct 21185) O'ROURKE & ASSOCIATES, LLC 27 Pine Street New Canaan, CT 06840 Telephone: (203) 966-6664 Facsimile: (203) 966-5710 Email: [email protected] (Counsel for Plaintiff)

Case 3:03-cv-00986-JCH

Document 33

Filed 03/19/2004

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CERTIFICATE OF SERVICE The undersigned, a member of the bar of this Court, hereby certifies that on this 19th day of March, 2004, the foregoing was served on the following counsel of record via facsimile and First Class Mail; postage prepaid:

Peter M. Schultz, Esq. PAUL, HASTINGS, JANOFSKY & WALKER, LLP 1055 Washington Boulevard Stamford, CT 06901-2217 Telephone: (203) 961-7400 Facsimile: (203) 359-3031

Jeffrey M. McCormick

Digitally signed by Jeffrey M. McCormick DN: CN = Jeffrey M. McCormick, C = US, O = O'Rourke Date: 2004.03.19 12:24:41 05'00'

________________________________ Jeffrey M. McCormick