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

Case 3:03-cv-00597—lV|FtK Document 118 Filed 12/28/2004 Page 1 of 4
UNITED STATES DISTRICT COURT
DISTRICT OF CONNECTICUT
BILL L. COUVEIA, AS ADMINISTRATOR : CIVIL ACTION
Plaintiff : NO. 303CV 597 l\/IRK
v.
SIG SIMONAZZI NORTH AMERICA, INC.
DefendantfThird—Party Plaintiff :
v.
SASIB FOOD MACHINERY MV, SPA
`€l>”Jl1iLfl—Party Defendants DECEMBER 28, 2004
Issues for Conference
Scheduled for January 4, 2005
After conferring in an effort to resolve issues without involving the Court, the
Parties respectfully submit this list of issues which it is expected will require the
assistance during the conference now scheduled for January 4, 2005, at 4:30 P.M.
1. Depositions of C.l.R. and Dry Products, by Alberto Piaser: The defendant
and plaintiff contend that they have not completed the deposition of this witness, and
are willing to complete his deposition by videoconference. Third—party defendants
contend that his deposition is complete.
2. Deposition of Sasib Food Machinery and Sasib Bakery Italia, by Andrea
Silvestrorriz The defendant and plaintiff contend that they have not completed the
deposition of this witness, and are willing to complete his deposition by
videoconference. Third—party defendants contend that his deposition is complete.
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Case 3:03-cv-00597—lV|RK Document 118 Filed 12/28/2004 Page 2 of 4
3. Compliance by Third-Party Defendants with Jurisdictional Discovery
Reguests: The Third-Party Plaintiff contends that the Third-Party Defendants have not
adequately answered the jurisdictional discovery requests. Third-Party Defendants
disagree.
4. Compliance by Third-Party Defendants with Document Demands: Third-
Party Plaintiff has served its First, Second, and Third Requests for Production of
Documents on C.I.R. and Dry Products, and its First and Second Requests for
Production of Documents on Sasib Food and Sasib Bakery. Third-Party Plaintiff
contends that CIR and Dry Products have not produced all documents responsive to the
First and Second Requests for Production of Documents and Sasib Food and Sasib
Bakery have not produced all documents responsive to the First Request for Production
of Documents. Third-Party Defendants disagree. Responses to the Third Request for
Production of Documents as to CIR and Dry Products and the Second Request for
Production of Documents as to Sasib Food and Sasib Bakery are not yet due; however,
Third-Party Defendants have objected to the Requests for Production of Documents.
The Third-Party Plaintiff will diligently attempt to have a meet and confer with the Third-
Party Defendants regarding the objections in advance of the January 4, 2005
conference call.
I 5. Amendment of Third-Party Complaint: The defendant will be filing this
week a motion for leave to amend the third—party complaint.
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Case 3:03-cv-00597—lV|RK Document 118 Filed 12/28/2004 Page 3 of 4
6. Extension of Discovery Schedule: The defendant contends that an
extension of 30 days is needed to the discovery schedule, in order to complete the
pending depositions, undertake (if necessary) foreign depositions, and obtain responses
to corporate structure and control discovery requests. The Third-Party Defendants
oppose this extension, in part. The Plaintiff does not object to such extension.
Respectfully submitted,
DEFENDANT/THIRD PARTY PLAINTIFF
Patri l\/l. Birney _-M-“
Feder Bar No. ct19875
l-lallor n & Sage LLP
One r' oodwin Square
Hartford, CT 06103
(860) 522-6103
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Case 3:03-cv-00597—lV|RK Document 118 Filed 12/28/2004 Page 4 of 4
CERTIFICATION
This is to certify that on this 28th day of December 2004, I hereby sent a copy of
the foregoing via Federal Express or regular mail to:
Richard J. Sullivan, Esq.
Sullivan & Sullivan, LLP
31 Washington St.
Wellesley, l\/lA 02481
Attorneys for Plaintiff
Deborah S. Russo, Esq.
Day, Berry & Howard
CityPlace
Hartford, CT 06103
Attorneys for Third—Party Defendants
Jonathan l\/Iazer, Esq.
John R. Horan, Esq.
Fox Horan & Camerini
825 Third Avenue
New York, NY 10022
Attorneys for Third—Party Defencg
Pauli; II/l. Blrney
630317.10-ISFP) “/
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