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

Case 3:O3—cv-00368-IVIRK Document 43 Filed 07/O9/2004 Page 1 of 3
UNITED STATES DISTRICT COURT
DISTRICT OF CONNECTICUT
....................................................... X
GREGORY A. BLOCH, ANNE C. BLOCH,:
GREGORY A. BLOCH, ANNE C. BLOCH :
as TRUSTEES FOR THE BENEFIT OF :
TRIAD ART GROUP, INC.’S EMPLOYEE: Index No.: 3:03 CV 0368 (MRK)
STOCK OWNERSHIP TRUST, ANNE C. :
BLOCH as CUSTODIAN FOR THE :
BENEFIT OF LUCAS CRETZMEYER, : July 8, 2004
TRIAD ART GROUP, INC., :
TRIAD ART GROUP PUBLISHING, INC., :
Plaintiffs,
vs. l
FINANCIAL WEST GROUP, and.
PATRICK SAHLI, :
Defendants.
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DEFENDANT FINANCIAL WEST GROUP’S
MOTION FOR ENLARGEMENT OF TIME
Pursuant to Fed.R.Civ.P. 6(b), the undersigned Defendant Financial West Group
("FWG") respectfully requests that the period of time within which this Honorable Court
has ordered the parties to file a Joint Trial Brief be enlarged up to and including August 31,
2004. The reason for said enlargement is that, while substantial discovery has been
exchanged, the parties to the above-captioned action have, as of yet, not completed
discovery within a sufficient amount of time to enable them to file their joint trial brief on or
before July 15, 2004.

Case 3:O3—cv-00368-IVIBK Document 43 Filed 07/O9/2004 Page 2 of 3
In this regard, the Plaintiffs provided Defendant FWG with their expert disclosure
for damages (Plaintiffs’ "Expert Report") on June 3, 2004. The Plaintiffs have not filed a
motion to enlarge the time period to serve their Expert Report, which was initially due on
or before November 14, 2003 (eight months ago) pursuant to the Report of Parties’
Planning Meeting (the "Parties’ Report"). However, in February of this year, the
Plaintiffs moved to extend the Discovery Period on consent, which this Honorable Court
granted, extending all discovery, including discovery relating to expert witnesses, to be
completed by May 29, 2004. As such, Defendant FWG reserves the right to depose the
Plaintiffs’ expert witness to the extent that such witness is permitted, and further reserves
its right to obtain and disclose its own expert witness. A telephone Status Conference is
scheduled in connection with this matter for Thursday, July 22, 2004 at 4:30 p.m., during
which we hope to resolve these matters.
WHERERFORE, the undersigned respectfully requests that this Court find that good
cause exists to enlarge the period of time within which to comply with this Court’s Order
that the parties file their Joint Trial Brief on or before July 15, 2004.
Dated: July 8, 2004
WINGET, SPADAFORA & SCHWARTZBERG, LLP
Attorneys for Defendant
Financial West Group
By:
Dianna D. McCarthy (ct24874)
45 Broadway, 19th Floor
New York, New York 10006
Phone: (212) 221-6900
Fax: (212) 221-6989
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Case 3:O3—cv-00368-IVIRK Document 43 Filed 07/O9/2004 Page 3 of 3
CERTIFICATION OF SERVICE
THIS IS TO CERTIFY that a copy of the foregoing was sent via regular mail on
this date to:
Daniel L. Schwartz (ct09862)
Day, Berry & Howard LLP
One Canterbury Green
Stamford, Connecticut 06901
Tel: (203) 977-7300
Fax: (203) 977-7301
[email protected]
(Attorneys for Plainl%v)
Patrick Sahli
P.O. Box K-1
Carmel, California 93921
Phone: (831) 626-5503
Cell: (831) 236-0413
Fax: (831) 626-4327
(Pro se Defendant)
Dated: July 8, 2004
Dianna D. McCarthy
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