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

Case 3:03-cv-00410-DJS

Document 22

Filed 03/01/2004

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UNITED STATES DISTRICT COURT DISTRICT OF CONNECTICUT

HEIDI E. SCHROEDER, Plaintiff VS. ACMI CORPORATION, Defendant

: : : : : : :

CIVIL ACTION NO. 3:03CV 0410 (MRK)

MARCH 1, 2004

UNOPPOSED MOTION TO MODIFY SCHEDULING ORDER The undersigned defendant, ACMI Corporation, respectfully requests a further modification of the Court's Scheduling Order dated January 8, 2004. This modification is necessary because, through no fault of the defendant, the defendant was unable to complete the deposition of the plaintiff's expert, F. Carl Mueller, M.D., within the allotted time period. As such, the defendant requests the following modifications to the Scheduling Order: 1. That the defendant be allowed forty-five (45) additional days, up to and

including April 19, 2004, to complete depositions of the plaintiff's experts; 2. That the plaintiff be given forty-five (45) additional days, up to and

including June 21, 2004, to complete depositions of the defendant's experts; 3. That the deadline for completing discovery be extended forty-five (45)

days, up to and including May 6, 2004; 3. That the defendant be allowed forty-five (45) additional days, up to and

including July 23, 2004, to file dispositive motions;

One Goodwin Square 225 Asylum Street Hartford, CT 06103

HALLORAN & SAGE LLP

Phone (860) 522-6103 Fax (860) 548-0006 Juris No. 26105

Case 3:03-cv-00410-DJS

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Filed 03/01/2004

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4.

That the Parties Joint Trial memorandum be due on August 23, 2004, in

the event that no dispositive motions are filed; 5. That, if no dispositive motions are filed, the case will be considered trial

ready on August 23, 2004. The defendant began the deposition of Dr. Mueller on February 23, 2004 at 2:00 p.m., but was unable to complete the deposition before Dr. Mueller's 4:00 p.m. appointment with a patient. Because of the busy schedule of Dr. Mueller, as well as of the parties and attorneys for the defendant and plaintiff, the parties have been unable to schedule the remainder of Dr. Mueller's deposition within the timeframe allowable under the Court's order. Granting an extension of forty-five days would allow an adequate opportunity to complete Dr. Mueller's deposition, given the hectic schedules involved, and in the event that the deposition scheduled for March 4, 2004 of plaintiff's expert Alan Falkoff, M.D. cannot be completed on that date, allows for the conclusion of that deposition. The deadlines subsequent to the deadline for deposing plaintiff's experts should also be moved to allow the parties a fair opportunity to complete the required discovery in this case. In support of this Motion, the undersigned represents that he has contacted plaintiff's counsel, Kathryn Emmett, who has indicated that she has no objection to this motion. This is the defendant's second motion for extension of time with respect to this time limitation.

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One Goodwin Square 225 Asylum Street Hartford, CT 06103

HALLORAN & SAGE LLP

Phone (860) 522-6103 Fax (860) 548-0006 Juris No. 26105

Case 3:03-cv-00410-DJS

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Filed 03/01/2004

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THE DEFENDANT: ACMI CORPORATION

By James M. Sconzo Fed Bar # ct04571 and Jonathan C. Sterling Fed Bar # ct24576 of HALLORAN & SAGE LLP One Goodwin Square 225 Asylum Street Hartford, CT 06103 (860) 522-6103

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One Goodwin Square 225 Asylum Street Hartford, CT 06103

HALLORAN & SAGE LLP

Phone (860) 522-6103 Fax (860) 548-0006 Juris No. 26105

Case 3:03-cv-00410-DJS

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Filed 03/01/2004

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CERTIFICATION This is to certify that on this 1st day of March, 2004, I hereby mailed a copy of the foregoing to: Kathryn Emmett, Esq. Christine Caulfield, Esq. Emmett & Glander 45 Franklin Street Stamford, CT 06901

Jonathan C. Sterling

521137.1(HSFP)

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One Goodwin Square 225 Asylum Street Hartford, CT 06103

HALLORAN & SAGE LLP

Phone (860) 522-6103 Fax (860) 548-0006 Juris No. 26105