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

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.. _ Cgsjgd)3-cv-009295AWT Document 70 Filed 01/10/2006 Page 1 of 2
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UNITED STATE DISTRICT COURT , _ _
DISTRICT OF CONNECTICUT: * ' `
(Hartford)
NICHOLAS SICONOLF1, ET AL ; W __, I P N U __ i
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V. : NO.: 3.:03, CV .929 (AWT)
RICHARD BERNAUD AND CHRISTOPHER I ` O
~ PAOLETTI : JANUARY 9, 2006
MOTION TO EXTEND TIME TO FILE JOINT TRIAL MEMORANDUM
.. The plaintiff requests that the parties be given until Friday, September 15, 2006 within
which to tile the joint trial memorandum.
The undcrsigned’s appearance was tiled only on December 13, 2005. A cursory
review ofthe plaintiffs former counscl’s file indicates that additional discovery on the part of
the plaintiff must take place, to wit, depositions of at least four individuals, including the
defendants. In addition to the press ofthis firm’s legal business in existence prior to the tiling
of the undersigned’s appearance in this case, the undersigned needs time to consult with the i
plaintiff potential witnesses and thoroughly review all ofthe documents contained in
plaintiffs former counsel’s tile. The plaintiff s former counsel’s tile stands a full foot in
height and fills the entire volume of a standard letter-sized tile storage box.
This is the plaintiffs first such request to extend time for the tiling ofthe joint trial
memorandum. The undersigned contacted opposing counsel who stated that he objected to
this request.
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‘· I · Case 3:03-cv-0092?—AWT Document 70 Filed 01/10/2006 Page 2 of 2
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RESPECTFULLY SUBMITTED,
NICHOLAS SICONOLFI, ET AL
THE PLAINTIFF
BY: _ {
[ ATTY. ERSKINE D. c OSH `
FEDERAL BAR NO. C 9743
THE LAW OFFICES OF ERSKINE D. McINTOSH, P.C.
3129 WHITNEY AVENUE, SECOND FLOOR
HAMDEN, CONN. 06518-2364
TEL. NO. (203) 787-9994
FAX N0. (203) 848-1213
QRTIFICATION
This is to certify that a copy ofthe foregoing was sent by fax/first-class mail, postage
prepaid on this the 9th day of January, 2006 to:
i
Atty. Stuart E. Brown [860-296-8494] i
Hassett & George, P.C.
555 Franklin Avenue
Hartford, CT 06114 § ,
ATTY. ERSKINE D TOSH
19 Motion—Extensi0n Joint Triai Memo
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