Free Response - District Court of Connecticut - Connecticut

Case 3:03-cv-00977-CFD

Document 14

Filed 02/22/2005

Page 1 of 2

UNITED STATES DISTRICT COURT DISTRICT OF CONNECTICUT

WENDELL HARP and ARCHITECTS ENVIRONMENTAL COLLABORATIVE INTERNATIONAL, P.C. VS. JOHN DeSTEFANO, CITY OF NEW HAVEN and NEW HAVEN BOARD OF EDUCATION

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NO. 3:03CV977(CFD)

FEBRUARY 20, 2005

PLAINTIFFS' LOCAL RULE 41(a) EXPLANATION

Pursuant to the Order of this Court entered on February 8, 2005, the plaintiffs submit the following explanation for the delay in bringing this case to trial: Discovery in this case has closed and the time for dispositive motions has expired. The Joint Trial Memorandum was to be filed in the fall of 2004, pursuant to this court's scheduling order. However, at approximately that time, Attorney Martin S. Echter, whose appearance still is on file on behalf of the defendants, was forced out of his position as Deputy Corporation Counsel for the City of New Haven. For several months, no other attorney appeared on behalf of the defendants. Attorney Kone has only very recently filed her appearance. By this time, she presumably has had sufficient time to become familiar with the case. Accordingly, the plaintiffs respectfully ask that the court direct the filing of a Joint Trial Memorandum on or before May 1, 2005. At that time, this case will be ready for trial.

Case 3:03-cv-00977-CFD

Document 14

Filed 02/22/2005

Page 2 of 2

For the foregoing reasons, this case should not be dismissed.

THE PLAINTIFFS

BY:______________________________ JOHN R. WILLIAMS (ct00215) 51 Elm Street New Haven, CT 06510 203/562-9931 FAX: 203/776-9494 E-Mail: [email protected] Their Attorney

CERTIFICATION OF SERVICE On the date above stated, a copy hereof was mailed to Attorney Carolyn W. Kone at Brenner, Saltzman & Wallman LLP, 271 Whitney Avenue, New Haven, CT 06511 [E-Mail: [email protected]].

__________________________________ JOHN R. WILLIAMS