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

Case 3:03-cv-00973-DJS

Document 38

Filed 07/20/2004

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UNITED STATES DISTRICT COURT DISTRICT OF CONNECTICUT : : : v. : : STATE OF CONNECTICUT, : DEPARTMENT OF TRANSPORTATION, : Defendant. : LISA TILUM, Plaintiff, CIVIL ACTION NO. 3:03CV0973(DJS)

JULY 16, 2004

MOTION FOR MODIFICATION OF SCHEDULING ORDER The Defendant Department of Transportation respectfully requests a modification in the existing scheduling order, which requires the parties to submit a Joint Trial Memorandum on July 23, and for the case to be trail-ready on August 2, 2004. Defendant requests that these dates be modified to August 13, 2004, and September 1, 2004, respectively. In support of this motion, Defendant represents as follows: 1. 2. Counsel for the plaintiff has no objection to this proposed modification. Due to the volume of documents involved, and the different places within the

Department that they were stored, defendant took longer to respond to discovery than anticipated. This has somewhat set back efforts to timely complete the Joint Trial Memorandum. 3. Even if the trial memorandum could be prepared by July 23, both trial counsel

have vacations scheduled for August which would be difficult to move, and it is not easy getting witnesses during that month either.

Case 3:03-cv-00973-DJS

Document 38

Filed 07/20/2004

Page 2 of 3

WHEREFORE, the defendant respectfully requests that the Scheduling Order be modified to permit the parties to file their Joint Trial Memorandum by August 13, 2004, and to have the case ready for trial on September 1, 2004. DEFENDANT STATE OF CONNECTICUT DEPARTMENT OF TRANSPORTATION BY: RICHARD BLUMENTHAL ATTORNEY GENERAL

____________________________________ ______ Mark P. Kindall Assistant Attorney General Federal Bar No. 13797 55 Elm Street P.O. Box 120 Hartford, CT 06141-0120 Tel: (860) 808-5250 Fax: (860) 808-5386

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Case 3:03-cv-00973-DJS

Document 38

Filed 07/20/2004

Page 3 of 3

CERTIFICATION

I hereby certify that a copy of the foregoing Motion was mailed in accordance with Rule 5(b) of the Federal Rules of Civil Procedure on this 16th day of July, 2004, first class postage prepaid to: Kathleen Eldergill, Esq. BECK & ELDERGILL, P.C. 447 Center Street Manchester, CT 06040 _________________________________ Mark P. Kindall Assistant Attorney General