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

Case 3:03-cv-00386-AWT

Document 64

Filed 04/13/2005

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UNITED STATES DISTRICT COURT DISTRICT OF CONNECTICUT

EUNICE SMITH, Plaintiff v. STATE OF CONNECTICUT, DEPARTMENT OF CORRECTION, Defendant

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CIVIL ACTION NO. 3:03CV00386(AWT)

APRIL 12, 2005

MOTION FOR MODIFICATION OF THE SCHEDULING ORDER

The defendants, through counsel, respectfully request an order to modify the existing Scheduling Order for the filing of dispositive motions to August 9, 2005. In support of this motion, the defendants represent as follows: 1. The current Scheduling Order set the deadline for filing dispositive

motions for April 18, 2005. 2. The parties have a scheduled settlement conference with Magistrate Judge

Martinez on June 9, 2005. 3. In the event that this case can be settled, and to avoid an unnecessary

expenditure of needless time on the part of all parties and the court, the defendants respectfully request the aforesaid extension. 4. Additionally, the file in the above-captioned matter is voluminous and,

inasmuch as it entails several years of litigation, additional time is required to review and compile material. 5. This is defendants' first request to modify the Scheduling Order.

Case 3:03-cv-00386-AWT

Document 64

Filed 04/13/2005

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6.

Pursuant to Local Rule 7(b), the undersigned contacted plaintiff's counsel,

Cynthia Jennings, Esq., and she has NO OBJECTION to this motion. WHEREFORE, the defendants respectfully request a modification of the Scheduling Order, resetting the deadline for the filing of dispositive motions to August 9, 2005. DEFENDANT, STATE OF CONNECTICUT, DEPARTMENT OF CORRECTION RICHARD BLUMENTHAL ATTORNEY GENERAL

BY:

____________________________________ _________ Jane B. Emons Assistant Attorney General Federal Bar No. 16515 55 Elm Street - P.O. Box 120 Hartford, CT 06141-0120 Tel: (860) 808-5340 Fax: (860) 808-5383 Email: [email protected]

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Case 3:03-cv-00386-AWT

Document 64

Filed 04/13/2005

Page 3 of 3

CERTIFICATION

I hereby certify that a copy of the foregoing Motion for Modification of the Scheduling Order, was mailed this 12th day of April, 2005, first class postage prepaid to: Cynthia Jennings, Esq. The Barrister Law Group 211 State Street, 2nd Floor Bridgeport, CT 06604

___________________________ Jane B. Emons Assistant Attorney General

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