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

Case 3:03-cv-00376-SRU Document 13 Filed O1/16/2004 Page 1 of 3
UNITED STATES DISTRICT COURT
for the
DISTRICT OF CONNECTICUT
ADRIANO B. BRANCO
Plaintiff, :
: Civil No. 3:03C`\/376(SRU)
v. :
SHAW’S SUPERMARKETS, INC., JANUARY i5, 2004
Defendant. :
MOTION FOR MODIFICATION OF SCHEDULING ORDER
Pursuant to the Federal Rules of Civil Procedure and Local Rule 7 of this Court,
the Defendant in the abovecaptioned matter respectfully requests a modification of the
scheduling order and seeks a thirty (30) day extension of time related to the discovery,
specifically the dispositive motion deadline. ln support of this motion, Defendant states:
1. On April 25, 2003, the Honorable Judge Stefan R. Underhill endorsed the
Report of Parties Planning Meeting which set the deadlines for completing discovery to
February l, 2004 and the filing of dispositive motions to March 1, 2004.
2. Plaintiffs counsel has been contacted and does not object to this request.
3. Despite diligent efforts by counsel for both parties, the plaintiff s
deposition has not been taken due to conflicts with the schedule of plaintiff and plaiiitiffs
counsel. The proposed modification ofthe scheduling order, allowing a thirty (30) day extension
of time, up to and including March l, 2004, will enable the parties to complete the remaining
deposition and finalize discovery. Also, in accordance with the extension • time allowed for
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Case 3:03-cv-00376-SRU Document 13 Filed O1/16/2004 Page 2 of 3
discovery, the Defendant seeks a thirty (30) day extension of time, up to and including April 1,
2004, for the filing of dispositive motions.
4. This is Defendants first request for modification of the scheduling order
as it is related to discovery and dispositive motions.
WHEREFORE, Defendant respectfully moves for a thirty (30) day extension of
time to modify the Scheduling Order to extend the discovery deadline through to March I, 2004,
and the dispositive motion deadline through to April 1, 2004.
DEFENDANT,
SI-IAW’S SUPERMARKETS, INC.,
I ’ J
Byr
Wiliiai ony (ct 17865)
anthon \ ·_ sonlewiseom
nsiiy 1,. ct mass)
CiI1ll'l[CQ.}·21Ci(SOI`1l€WlS.CD1Tl
Jackson Lewis LLP
55 Farmington Avenue, Suite 1200
Hartford, CT 06105
(860) 522—0404 (phone)
(860) 247-1330 (fax)
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Case 3:03-cv-00376-SRU Document 13 Filed O1/16/2004 Page 3 of 3
CERTIFICATION OF SERVICE
This is to certify that a copy of the foregoing was sent by first class mail, postage
prepaid on this 15m day of January, 2004, to the foliowing counsel of record:
Jolm R. Williams
Williams and Pattis, LLC
51 Elm Street
New Haven, CT 06510
203-562-99.31
, Q,
/ A'“ JA
H
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