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

ase 3:03-cv-00455-MRK Document 14 Filed 10/28/2003 Page 1 of 2 I
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UNIT§}\S;I§’&S DISTRICT COURT
DI II-Q RI$g[;“\(1)`i1Er{Z‘QhJNECTICUT 1
KERIN CARMODY, tm U .,1 nrfi ¥1`¥“·fl`a. ·
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1*% : CIVIL ACTION NO.
VS : 303(ZV00456 (MRK)
K()HL’S DEPARTMENT STORES, INC.
DEFENDANT : OCTOBER 27, 2003
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MOTION FOR EXTENSION OE THE PRETRIAL 1
SCI-IEDULING ORDER 1
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The Plaintiff Kerin Carmody, in the above-captioned matter, pursuant to Local Rule 1
7(b), respectiiilly request a thirty day extension of the Pretrial Scheduling Order, or such
additional time as this court may determine, to disclose expert witnesses and the provision of the
expert report irom receipt of Defendant‘s responses to Plaintiff‘s Interrogatories and Production
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dated August 25, 2003. Plaintiff would further request a corresponding extension ofthe time to
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depo se expert witnesses. In support of this motion the Plaintiff states the following: 1
l. No previous extension of the Pretrial Scheduling Order has been requested. 1
2. On May 06, 2003 the Court (Arterton, U.S.D.J.) issued scheduling orders including that I
discovery shall be completed on or before February 01, 2004 and that Plaintiffs expert
witnesses shall provide expert witness report(s) to be served by November Ol, 2003.
3. Pursuant to discussion with the Defendant, the Plaintiff iirst set of Interrogatories and
Production dated August 25, 2003 was served on the Defendant. The Defendant by letter dated 1
September 15, 2003 requested revisions of certain interrogatories which the parties have
discussed and clarified. A response to said interrogatories is presently pending.
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F ase 3:03-cv-OO45(6-IYIRK Document 14 Filed 10/28/2003 Page 2 of 2
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4. In the absence of a response to Plaintiff s Interrogatories (ie. the floor composition of g
the subject premises) the Plaintiff s safety engineer cannot provide an expert report. l
5. The.Defendant has been contacted regarding this Motion for Extension and has indicated f
that there is no objection to this motion. _
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6. This extension of time will not delay the progression ofthe case as to discovery and l
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other matters, including a special masters presently scheduled for December 10, 2003.
WHEREFORE, based on the foregoing the Plaintiif respectfully requests this Court
grant an extension of the Pretrial Scheduling Orders for expert disclosures and depositions.
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THE PLAINTIFF, j
KERIN CARMODY T
RICHARD H. GREENE, (ct.08905) {
431 HOWE AVENUE Q
P.O. BOX 2042 HUNTINGTON STATION l
SHELTON, CT 06484 l
(203) 924 - 9361
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CERTTEICATION

This is to certiiy that a copy ofthe foregoing Motion for Extension has been mailed on
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this date, October 27, 2003, postage prepaid, to all counsel and pro se parties of record: l
Barry Beletsky, Esq.
Ricco & Beletsky Q
310 Main Street, Suite B /,,
East Haven, CT 06512 /%%OL—_"/{ ,__.
Richard H. Greene l
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