Free Motion for Conference - District Court of Connecticut - Connecticut

Case 3:03-cv-00986-JCH Document 138 Filed 08/18/2005 Page 1 of 3
UNITED STATES DISTRICT COURT
DISTRICT OF CONNECTICUT
SUSAN E. WOOD CIVIL ACTION NO.
3:03 CV 986(J CH)
Plaintiff,
· against · August 17, 2005
SEMPRA ENERGY TRADING CORP.
Defendant.
DEFENDANT’S MOTION FOR ORDER TO CONVENE
SCHEDULING CONFERENCE
Defendant Sempra Energy Trading Corp. ("Sempra"), hereby moves that the
Court order a scheduling conference be convened, via teleconference, to attempt to find an
altemative date other than August 30, 2005, to reconnnence trial in the above matter.
Following the parties scheduling conference on August 16, 2005, counsel for
Sempra contacted their client about the proposed scheduling change and attempted to contact the
non-party witnesses. At least two of Sempra’s witnesses have scheduling conflicts with the
proposed August 30th trial date. In addition, Sempra’s client representative and General Counsel
is unavailable on that date. Elizabeth Dwyer is scheduled to be in Scotland with her family on
August 30th. Jacqueline Mitchell is likewise scheduled to be on vacation with her family during
the week of August 29th. Attomey Michael Goldstein will be retuming on the morning of
August 30th on an overnight flight from Israel.
Further, counsel has yet to be able to get in contact with the non-party witnesses
to determine their availability. However, it is very possible that they may also have a conflict

Case 3:03-cv-00986--ICH Document 138 Filed 08/18/2005 Page 2 of 3
given the fact that the last week in August is typically a time when people vacation with their
families. For these reasons, Sempra respectiitlly requests that the Court convene a scheduling
conference to determine an alterative date to recommence trial in the above matter.
Respectihlly submitted,
By: L6
M C. Dollarhide (ct12251)
Raymond W. Bertrand (ct22968)
PAUL, HASTINGS, JANOFSKY & WALKER
LLP
1055 Washington Boulevard
Stamford, CT 06901-2217
Telephone: (203) 961-7400
Facsimile: (203) 359-3031
Email [email protected]
[email protected]
Counsel for Defendant
Sempra Energy Trading Corp.
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Case 3:03-cv-00986-JCH Document 138 Filed 08/18/2005 Page 3 of 3
CERTIFICATE OF SERVICE
This is to certify that Defendant’s Motion for Order to Convene Scheduling Conference
was sent on this 17th day of August, 2005, via U.S. mail and facsimile to:
Brendan J. O’Rourke, Esq. -
O’Rourke & Associates, LLP
27 Pine Street
New Canaan, CT 06840
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Ra ond W. Bertrand
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