Free Notice (Other) - District Court of Connecticut - Connecticut

Case 3:03-cv-00943-AWT Document 51 Filed 05/15/2006 Page 1 of 1
PHILIP RUSSELL, L.L.C.
ATTORNEYS AT LAW
PHILIP RussELL*+ (203) 661`4200 66 FIELD Pomr ROAD
JAMES PASTORE RO BOX 1437
GREENW% cr 06836
of counsel: FAX 6
HAROLD 1-1. DEAN (363) 66*3666 `
* MEMBER CONNECTICUT AND NEW YORK BAR _
+ BOARD CERTIFIED '
CRIMINAL TRIAL ADVOCACY
NATIONAL BOARD OF TRIAL ADVOCACY ‘
May 15, 2006
The Honorable Donna F. Martinez
United States District Court Magistrate
450 Main Street
Hartford, CT 06103
Re: Session v. Rodriguez, et al.
Civil Docket No.: 3:03 CV 00943 (AWT)
Dear Magistrate Martinez:
I received your orders following our telephone conference on May 10, 2006 regarding
discovery. After speaking to my adversaries, we were under the impression that no scheduling
orders would be entered until after the time period allotted by your Honor regarding outstanding
written discovery and motions to compel, if necessary.
I would respectfully request your Honor to reconsider the orders in order to allow
plaintiff to complete discovery by August 15, 2006, and dispositive motions filed by September
15, 2006. Attomey Beamon consents to this request, however, Attorney Baier expressed an
objection.
The reason for this request is that plaintiff plans to schedule eighteen (18) depositions.
We had previously scheduled them in September 2005, rescheduled them for February 2006, and
now are faced with having to schedule them around plaintiff s counsel’s trial calendar and a
holiday week when it is expected that some of the officers may be on vacation leave.
Very truly yours,
Karen L. Mayer
KLM/ sr
cc: Stephanie Baier, Esq.
Jonathan Beamon, Esq.