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

Case 3:03-cv-00930-CFD

Document 56

Filed 03/02/2004

Page 1 of 3

UNITED STATES DISTRICT COURT DISTRICT OF CONNECTICUT ROBERT T. PARKER Plaintiff, : : : v. : : HARTFORD PARKING AUTHORITY and : MERYTH DEAN WILLIAMS, Chairperson,: Hartford Parking Authority in her official : and individual capacities and : SERAFIN MENDEZ MENDEZ, Treasurer, : Hartford Parking Authority in his official : and individual capacities, : Defendants. : CIVIL ACTION NO. 3:03cv 930 (CFD)

MARCH 1, 2004

JOINT MOTION FOR EXTENSION OF TIME Pursuant to Rule 6(b) of the Federal Rules of Civil Procedure and Rule 9(b) of the Local Rules of Civil Procedure for the United States District Court, District of Connecticut, Defendants, Hartford Parking Authority, Meryth Dean Williams and Serafin Mendez Mendez (collectively "Defendants"), and Plaintiff, Robert Parker, jointly move that the Court enter an order extending the deadline for completion of discovery in this matter from March 1, 2004 to June 7, 2004. The parties offer the following in support of this motion: 1. The deadline for the completion of discovery (pursuant to the Report of the Parties' Planning Meeting) is March 1, 2004. 2. The undersigned has conferred with Counsel for Plaintiff regarding this matter. Counsel for Plaintiff has indicated that he wishes to join in a motion requesting an additional fourteen weeks for the parties to complete all discovery in this matter.

Case 3:03-cv-00930-CFD

Document 56

Filed 03/02/2004

Page 2 of 3

3. 4.

This is the parties' first request for an extension of time regarding this deadline. Despite the fact that written and deposition discovery in this case is underway, additional time is needed for several reasons. First, Plaintiff incurred a delay in obtaining certain documents from a non-party witness that were needed in order to conduct other discovery. Second, a dispute arose in January during the deposition of Defendant Serafin Mendez Mendez ("Mendez") between Plaintiff and Defendants with regard to the appropriate scope of the attorney-client privilege. As a result of this dispute, Mendez's deposition was suspended and the depositions of at least three other individuals did not proceed.1

5.

Trial has not yet been scheduled in this matter. WHEREFORE, the parties respectfully request this Court to extend the deadline for the

completion of discovery to June 7, 2004.

The parties have prepared and intend to execute a stipulation which will resolve this dispute, at least in part, but anticipate that further disagreements will arise regarding whether or not certain communications are privileged. A discovery conference is currently scheduled with Magistrate Smith for March 22, 2004. -2-

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Case 3:03-cv-00930-CFD

Document 56

Filed 03/02/2004

Page 3 of 3

DEFENDANTS, HARTFORD PARKING AUTHORITY, MERYTH DEAN WILLIAMS and SERAFIN MENDEZ MENDEZ

By:___________________________________ Jill Hartley Fed. Bar No. CT 10570 Michael G. Albano Fed. Bar No. CT 21440 Sabia & Hartley, LLC 190 Trumbull Street, Suite 202 Hartford, CT 06103 Tel: (860) 541-2077 Fax: (860) 713-8944 CERTIFICATION I hereby certify that a copy of the foregoing was sent via U.S. Mail, first class, postage prepaid, on this 1st day of March, 2004 to: Eliot B. Gersten, Esq. Gersten & Clifford 214 Main Street Hartford, CT 06106 Jonathan L. Gould, Esq. 214 Main Street Hartford, CT 06106

_____________________________ Jill Hartley
E:\WPD OCS\HartfordParking\Parker\extend.time.discovery.cutoff.wpd

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