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

Case 3:03-cv-00943-AWT Document 158 Filed 03/20/2008 Page 1 of 3
UNITED STATES DISTRICT COURT
DISTRICT OF CONNECTICUT
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GARY SESSION, CIVIL ACTION NO.
Plaintiff 3:03-cv- 00943 (AWT)
EDWIN RODRIGUEZ, ET AL. MARCH 20, 2008
Defendants
MOTION FOR ENLARGEMENT OF TIME j
TO COMPLETE DISCOVERY §
Pursuant to Fed. R. Civ. P. 6(b) and Local Rule 7 (b)(2) the Plaintiff by the
undersigned respectfully move for an additional thirty (3 0) day enlargement of time up to
and including April 26, 2008 within which to complete discovery in this matter. The
Defendant through counsel consents to the granting of this Motion.
In support thereof, the Plaintiff represents as follows:
l. Discovery is currently scheduled to close on March 26, 2007.
2. On or about February 8, 2008, the Defendant filed a Motion for Protective
Order concerning his Internal Affairs file from the New Haven Police Department. The
Plaintiff subsequently moved to compel production of those records.
3. A hearing is scheduled on those motions for March 27, 2008, the day after
discovery is supposed to be completed.
4. At this juncture, Plaintiff anticipates taking only two further depositions,
those of the defendant Edwin Rodriguez and Detective Villeca of the New Haven Police
Department. Plaintiff cannot take the deposition of Mr. Rodriguez until the court rules on
the pending motions.

Case 3:03-cv-00943-AWT Document 158 Filed 03/20/2008 Page 2 of 3
5. There is also an outstanding Motion for Contempt and other relief directed
against Francisco Ortiz, the New Haven Police Chief. Counsel for Ortiz has been given
until March 25, 2008 within which to object to that Motion. There is also a pending
Motion to Quash a document subpoena issued by Plaintiff. Plaintiff has until April 8,
2008 within which to respond
6. In the event this Motion for Enlargement is granted, Plaintiff further seeks l
an enlargement of thirty (30) days for the filing of dispositive motions from the new
discovery closure date. N S
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7 The Defendant through counsel consents to the granting of this Motion.
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8. In the event that discovery is completed prior to April 26, 2008, the parties
will report that fact to the Court in order to hasten the completion of the remaining pre-
trial matters.
Wherefore, based upon the foregoing, the Plaintiff moves for an additional thirty
(3 0) day extension of time to complete discovery up to and including April 26, 2008.
THE PLAINTIFF
GARY SESSION
By /Roy S. Ward/
Roy S. Ward, Esq.
3695 Post Road, Suite 203
Southport, CT 06890
Tel: (203) 255-9829
Fax: (203) 255-9839
Email: [email protected]
: Fed. Bar. No. ctl 1618

Case 3:O3—cv-OO943—AWT Document 158 Filed O3/20/2008 Page 3 of 3
CERTIFICATION
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I hereby certify that on March 20, 2008 a copy of the foregoing was filed
electronically and served by mail on anyone unable to accept electronic filing. Notice of
this filing will be sent by e-mail to all parties by operation of the Court’s electronic filing l
system or by mail to anyone unable to accept electronic filing as indicated on the Notice ‘
of Electronic Filing. Parties may access this filing through the Court’s CM/ECF System.
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/Roy s. waidx
Roy S. Ward
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