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

ase 3:03-cv—O0974-CFD Document 35 Filed 04/22/2004 Page 1 of 3
UNITED STATES DISTRICT COURT
DISTRICT OF CONNECTICUT
AMERICAN BOARD OF : CIVIL ACTION NO.
ANESTHESIOLOGY, INC. : 3:03 CV 974(CFD)
Plaintiff,
JOHN STEPHEN NAULTY, M.D.
Defendant. APRIL 22, 2004
MOTION, ON CONSENT, FOR EXTENSION OF TIME
Pursuant to Local Rule 7 of the Local Rules of Civil Procedure for the District of
Connecticut, the plaintiff, the American Board of Anesthesiology, Inc. (the "ABA"),
respectfully moves this Court, on consent of the defendant, for an extension of the April 24,
2004 deadline by which the parties must fmalize and file an appropriate notice of dismissal
with the Court, by 13 days, up to and including May 7, 2004.
Good cause exists for the granting of this limited extension of time, because the
parties require this additional time to finalize the settlement of this action, which terms were
initially established at the settlement conference conducted by the Honorable Thomas P.
Smith on March 25, 2004.
This is the first request made by a party relating to this deadline. The undersigned
counsel has spoken to Attorney Carolyn Kone, counsel for the defendant, who indicated that
the defendant consents to the tiling of this Motion.
ORAL ARGUMENT NOT REQUESTED

ase 3:03-cv—00974-CFD Document 35 Filed 04/22/2004 Page 2 of 3
WHEREFORE, the ABA respectfully requests an extension of the April 24, 2004
deadline by which the parties must fmalize and file an appropriate notice of dismissal with the
Court, by 13 days, up to and including May 7, 2004.
PLAINTIFF,
AMERICAN BOARD OF ANESTHESIOLOGY,
INC.

By
harles L. Ho ard
Fed. Bar No. ct05366
Karen T. Staib
Fed. Bar No. ct2lll9
Shipman & Goodwin LLP
One American Row
Hartford, CT 06103
Telephone: (860) 251-5000
Facsimile: (860) 251-5699
E—mail: [email protected]
E-mail: [email protected]
Its Attorneys

ase 3:03-cv—00974-CFD Document 35 Filed 04/22/2004 Page 3 of 3
CERTIFICATION OF SERVICE
This is to certify that on this 22“" day of April 2004, a copy of the foregoing Motion,
On Consent, for Extension of Time was served via U.S. mail, postage prepaid, to:
Carolyn W. Kone
Kenneth Rosenthal
Brenner, Saltzman & Walhnan
271 Whitney Avenue
New Haven, CT 06511
gen T. Staib § Q
370105 v.0l