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

_ i Case 3:03—cv—00378-DJS Document 27 Filed 12/18/2003 Page 1 of 4
IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF CONNECTICUT
DONNA OWEN, )
)
Plaintiff, ) CIVIL ACTION NO.
) 3:03 CV 378 (DJS)
vs. )
)
GEORGIA—PACIFIC CORPORATION, )
)
Defendant. ) December 18, 2003
DEFENDANT’S UNOPPOSED MOTION TO EXTEND
THE DEADLINE FOR FILING DISPOSITIVE MOTIONS
Pursuant to Rules l6(b) and 6(b) of the Federal Rules of Civil Procedure, Defendant,
Georgia-Pacific Corporation ("Georgia-Paciiic" and/or “Defendant") with consent of the
Plaintiffs counsel and for good cause shown, moves the Court for a one-week extension of time
to file a dispositive motion in the above-captioned matter. In support of tl1is Motion, Defendant
states:
1. Pursuant to Rule l6(b) of the Federal Rules of Civil Procedure, a scheduling order
can be modified upon a "showing of good cause and by leave of the district court judge or, when
authorized by local rule, by a magistrate judge." Fed. R. Civ. P. l6(b);
2. The Parties have diligently conducted discovery; both serving and responding to
written discovery and taking depositions;
ORAL ARGUMENT NOT REQUESTED
TESTIMONY NOT REQUIRED

Did Case 3:03—cv—00378-DJS Document 27 Filed 12/18/2003 Page 2 of 4
3. Pursuant to this Court’s April 15, 2003 Order, discovery concluded on
December 5, 2003 and the deadline for filing dispositive motions is January 5, 2003;
4. The parties have not received certified deposition transcripts from the depositions
taken in this case. Counsel for Defendant has contacted the court reporting service that attended
the depositions, and understands that the transcription has been delayed due to a staff member’s
illness. Defendant anticipated that the certified transcript from Plaintiffs deposition would be
delivered on December 17, 2003, but it has yet to arrive. The court reporter has estimated that
the transcript from the deposition of Plaintiff s supervisor, Wayne Grant, will be completed by
December 19, 2002. Even if the transcript is completed by that date, the parties likely will not
receive the transcript until the week containing the Christmas holiday.
5. In light of the intervening Christmas and New Years’ holidays, Defendant
requires additional time to review the deposition transcripts and prepare its motion for summary
judgment and related pleadings. Accordingly, Defendant requests a one-week extension of time
to file its dispositive motion in this matter, through and including January 12, 2003.
6. Plaintiff has consented to this brief extension, and the granting of a one-week
extension of time to file a dispositive motion will not prejudice any party or delay the
proceedings in this matter.
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` _‘ if Case 3:03—cv—00378-DJS Document 27 Filed 12/18/2003 Page 3 of 4
WHEREFORE, for good cause shown, Defendant respectfully requests that the Court
enter an Order granting Defendant’s Unopposed Motion To Extend The Deadline To File
Dispositive Motions, and extending the dispositive motions deadline through and including
January 12, 2003.
. . /"
Respectfully submitted this {X day of December, 2003.
GEORGIA-PACIFIC CORPORATION
By: L ’(
Gre y . N es (CT06095)
MC ARTER & ENGLISH
CityPlace 1
185 Asylum Street
Hartford, Connecticut 06103-3495
Randall D. Avram (CT24717)
Richard D. Haygood (CT24718)
HUNTON & WILLIAMS
One Harmover Square, 14th Floor
Raleigh, North Carolina 27601
Telephone: (919) 899-3000
Facsimile: (919) 833-6352
Attorneys for Defendant
Georgia-Pacific Corporation
3

D Case 3:03—cv—00378-DJS Document 27 Filed 12/18/2003 Page 4 of 4
CERTIFICATE OF SERVICE
This is to certify that I have this date served DEFENDANT’S UNOPPOSED MOTION
TO EXTEND THE DEADLINE FOR FILING DISPOSITIVE MOTIONS by depositing a
true and correct copy of same in the United States mail with adequate first-class postage affixed
thereon, addressed as follows:
Stephen P. Homer, Esq.
Law Office of Stephen P. Horner
2183 Boston Post Rd.
Darien, CT 06820
. V6
This M day of December, 2003.
4
Greg y B o s
HA1zT1=o1; 605183.01
4