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

- Case 3:03-cv—OO369—DJS Document 18 Filed 11/14/2003 Page 1 of 3 I
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IN THE UNITED STATES DISTRICT COURT [QQ] NU"] g lj A IO; 5 O
FOR THE DISTRICT OF CONNECTICUT
LYNN B. KANIOS Civil Action No. 303CV3d§ UCgjIJR T I
Plaintiff, _
vs.
UST INC. and MARK ULIASZ,
Defendants. November 13, 2003 I
JOINT MOTION FOR EXTENSION OF TIME FOR DISCOVERY SCHEDULE
PLEASE TAKE NOTICE that pursuant to Federal Rules of Civil Procedure Rule 6(b) I
and Local Rules of Civil Procedure Rule 9(b)3, counsel for the Plaintiff and the Defendants in I
this matter hereby respectfully and jointly move to extend the time period for completion of I
discovery by sixty (60) days, or until February 2, 2004, and to correspondingly extend the
deadline for filing any dispositive motions to March 3, 2004. In support of good cause for the [
granting of this motion, counsel submit the following:
1. While a significant amount of discovery has already been completed in this
matter, the additional time is needed to take the deposition of several additional witnesses.
2. Scott R. Lucas, Esq. and Mary Canaday, Esq., counsel for plaintiff, were just
notified that they will be commencing a jury trial in Stamford Superior Court on December 2,
2003 and that trial is likely to span 2 to 3 weeks.
3. The additional time requested herein is also necessary to accommodate the travel .
schedules of the witnesses as well as the upcoming holidays. I
4. This is the first extension of time requested as to these time limitations.
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_ ~ i i Case 3:03-cv-OO3€9—)DJS Document 18 Filed 1 1/1C4¢5OO3 Page 2 0f 3
WHEREFORE, counsel for the Plaintiff and the Defendants jointly request that this i
Court extend the deadlines as set forth herein.
Respectfully submitted, l
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Scott . ‘ , sq. Mary A. amb della, Esq. l
Marti ucas & Chioffi LLP Epste B cke Green, P.C. l
177 Broad Street One Lan ark Square, Suite 1800 l
Stamford, CT 06901 Stamford, CT 06901
Federal Bar No. ct00517 Federal Bar No. ct05386
Counsel for Plaintiff Counsel for Defendants 1
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i . * Case 3:03-cv-0O3€9jDJS Document 18 Filed 11/1615003 Page 3 of 3 l
CERTIFICATION
The undersigned hereby certifies that a copy of the foregoing Joint Motion for Extension of I
Time for Discovery Schedule was sent via first class mail, postage prepaid, this 13m day of
November, 2003 to counsel of record for the plaintiff as follows: y
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Scott R. Lucas, Esq.
Martin, Lucas & Chioffi, LLP
177 Broad Street g
Stamford, CT 06901
égven J. Younes
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