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

"‘——"_1‘““ l
Case 3:03-cv-00958-MRK Document 18 Filed 1 1/14/2003 Page 1 of 2 1
1
UNITED STATES DISTRICT COURT 1
DISTRICT OF CONNECTICUT 17 1 1_ E 1] 1
--·--—--— ··-·-··- -------— ···—· ————-—---—------—— ·-·-····- ----------- X
CONAIR coR1>onArioN, ; 110,, 1t1 1 -,5 Fgl ‘[33 1
: Civil Action No. 303 CV 0958 (MRK)
plaintiff, ; U. S. lliixl HEC? _ Nin llA‘ftZ`ll.{JOHH. 1
v. :
EURASIA CONCEPTS, INC. :
A d.b.a. BIO IONIC, INC., : §
Defendant. :
....... ....... ._... .. .................. .. ............... .........X
1
PLAINTIFF’S CONSENTED MOTION TO EXTEND
COURT ORDERED DEADLINES
AND ORDER THEREON
Plaintiff Conair Corporation (hereinafter "Conair") moves the Court to extend the
deadlines ordered by the Court in its Order dated July 28, 2003 and in the parties’ case
management plan. Plaintiff proposes to extend the deadlines up to sixty days, or to such dates as
this Court deems appropriate. In support of its motion, Plaintiff states as follows: . 1
l. The parties continue to discuss settlement of this lawsuit. 1
2. While the parties have exchanged some discoverable information during settlement ,
discussions, the parties have not engaged in full discovery in anticipation of settlement.
3. The next deadline in this Court’s Order requires Plaintiff to produce expert reports by
1 .
November 28, 2003. In anticipation of settlement, the parties have not conducted enough 1
discovery in this case to submit reports.
4. Plaintiff hereby moves the Court to extend the deadlines in its July 28, 2003 Order and
in the parties’ case management plan by sixty days so that the parties may continue the ongoing E
settlement discussions, which both parties expect to be fruitful.
5. Counsel for Defendant, Brian Foley, Esq., joins in this motion.
1

ligl

1 1
Case 3:03-cv-00958-MRK Document 18 Filed 11/14/2003 Page 2 of 2 a
6. This motion is being made for good cause and not for purposes of delay. I
1
Dated: November l0, 2003 Respectfully submitted, i
I Anthony H. Handal (Ct Fed. # 03837)
Kirkpatrick & Lockhart, LLP
599 Lexington Avenue
New York, New York 10022
1 2t2—536—3900 ph
2l2—536—390l fax
Attorneys for Plaintiff p
CERTIFICATE OF SERVICE
I, Catherine R. Keenan, an associate with Kirkpatrick & Lockhart, LLP, counsel for Plaintiff,
Conair Corporation, hereby certify that a copy of the foregoing Plaintiffs Consented Motion to Extend
Deadlines and Order Thereon was served today, November 10, 2003, upon all parties by placing a copy of
Same in first class mail, postage prepaid, addressed as follows:
1
1
Brian T. Foley, Esq. I
McGovern & Associates
One Lafayette Place
Greenwich, CT 06830
Dated: November l0, 2003 By
' Catherine R. Ke an
1
1
. 1