Free Motion for Clarification - District Court of Connecticut - Connecticut

Case 3:02-cv-01302-JCH

Document 450

Filed 08/15/2005

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UNITED STATES DISTRICT COURT DISTRICT OF CONNECTICUT

SHAWN POULIOT, Plaintiff v.

PAUL ARPIN VAN LINES, INC. et al. Defendants

) ) ) ) ) ) ) ) ) )

CIVIL ACTION NO. 3:02 CV 1302 (JCH) JUDGE JANET C. HALL

August 12, 2005

JOINT MOTION FOR CLARIFICATION OF FINAL PRE-TRIAL ORDER AND DEADLINES INCORPORATED THEREIN NOW COME the parties, and jointly request clarification of the Court's Order regarding certain deadlines. In support of this motion, the parties state as follows: 1. 2. A Final Pre-Trial Order in this matter issued on May 9, 2005. The final pre-trial conference was originally scheduled for September 2, 2005. It has now been rescheduled by the Court to September 15, 2005. 3. The Final Pre-Trial Memorandum with attachments was duly filed by the parties on August 1, 2005. 4. Under the Final Pre-Trial Order, certain additional deadlines are all tied to the pre-trial conference date. Those deadlines are as follows: A. 7 days before the pre-trial conference, oppositions to motions in limine must be filed. B. 5 days before the pre-trial conference, the parties are to submit, as to experts, a biographical sketch, areas of expertise, a statement of each

Case 3:02-cv-01302-JCH

Document 450

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opinion, the basis of each opinion, and the material upon which each expert relies. C. 4 days before the pre-trial conference, each party must file objections to interrogatories and requests to admit designated by the other party. D. 3 days before the pre-trial conference, each party must file a memorandum addressing evidentiary issues regarding the Exhibits of the other party. E. 3 days before the pre-trial conference, the parties must file one complete set of exhibits in binders with Judge Hall. F. 1 day before the pre-trial conference, each party must file a glossary of medical terms to be used at trial. G. 72 hours before the pre-trial conference any request of trial counsel to be excused from the pre-trial conference must be filed. 5. Under the original Final Pre-Trial Order, therefore, each of these items would have been due between August 26 and September 1, 2005. 6. If these dates are now to run from the rescheduled pre-trial conference date, all items will be due between September 8 and September 14, 2005. 7. Pursuant to ECF notice issued directly by the Clerk's office, upon filing of each party's motions in limine on August 1, 2005, a different date of August 22, 2005 was set for responses to motions in limine. The parties jointly request that the date for further filings as contemplated by the Final Pre-Trial Order be set in accordance with the Final Pre-Trial Order. Therefore, the parties request as follows:

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Case 3:02-cv-01302-JCH

Document 450

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A. B.

Opposition to motions in limine be due on September 8, 2005; As to each expert witness, submission of a biographical sketch, areas of expertise, each opinion, basis of each opinion, material upon which each witness relies shall be due September 9, 2005;

C.

Objections to interrogatories and requests to admit designated by the other party shall be due September 9, 2005;

D.

A memorandum addressing evidentiary issues raised by the Exhibits of the other party shall be due September 12, 2005.

E.

One complete set of exhibits in binders shall be filed with Judge Hall by September 12, 2005.

F.

Each party must file a glossary of medical terms to be used at trial by September 14, 2005.

G.

Any request of trial counsel to be excused from the pre-trial conference must be filed by September 9, 2005.

Respectfully submitted,

/s/ Michael A. Stratton Michael A. Stratton, Esq., CT STRATTON FAXON 59 Elm Street New Haven, CT 06510 203-624-9500 [email protected]

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Case 3:02-cv-01302-JCH

Document 450

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/s/ Karen Frink Wolf Harold J. Friedman, Esq. CT 23785 Karen Frink Wolf, Esq. CT 26494 FRIEDMAN GAYTHWAITE WOLF & LEAVITT Six City Center, P.O. Box 4726 Portland, ME 04112-4726 (207) 761-0900 (207) 761-0186 (Fax) [email protected] [email protected]

CERTIFICATE OF SERVICE This is to certify that a copy of the foregoing was mailed via U.S. First Class Mail this 12th day of August, 2005 to the following:

Michael A. Stratton, Esq. Stratton Faxon 59 Elm Street New Haven, CT 06510 Thomas J. Grady, Esq. Lenihan Grady & Steele 6 Canal Street PO Box 541 Westerly, RI 02891-0541

/s/ Karen Frink Wolf Karen Frink Wolf, Esq. CT 26494

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