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

Case 3:01-cv-02163-RNC

Document 30

Filed 08/30/2005

Page 1 of 2

UNITED STATES DISTRICT COURT DISTRICT OF CONNECTICUT

MARY ANN JAGGER v. MOHAWK MOUNTAIN SKI AREA, INC. AND JAMES COURTOT

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NO.: 3:01CV2163 (RNC)

AUGUST 30, 2005

JOINT MOTION TO MODIFY SCHEDULING ORDER The parties hereby respectfully request the Court to modify the scheduling order in accordance with the attached supplemental Rule 26(f) report. The reasons for this joint request are that a number of depositions have not been completed owing to vacation schedules of the witnesses and counsel. Additionally, the plaintiff is still treating, and has not yet received a permanency rating from her treating doctor, Evan Rashkoff, M.D. Therefore, the plaintiff has been unable to prepare a final damages analysis. Once the plaintiff has completed treatment and all records have been produced, the defendant intends to retain the services of a medical expert. The parties submit that this request is for good cause and is not interposed merely to delay the trial.

Case 3:01-cv-02163-RNC

Document 30

Filed 08/30/2005

Page 2 of 2

Wherefore, the parties respectfully request that the motion to modify the scheduling order be approved.

PLAINTIFF MARY ANN JAGGER

DEFENDANTS, MOHAWK MOUNTAIN SKI SCHOOL, LLC AND JAMES COURTOT

By_/s/ Jack D. Miller_________ Jack D. Miller ct05300 Regnier, Taylor, Curran & Eddy CityPlace I, 28th Floor Hartford, CT 06103 (860) 249-9121 (860) 527-4343 (FAX) [email protected]

By__/s/ Philip T. Newbury, Jr.__ Philip T. Newbury, Jr. ct05283 Howd & Ludorf, LLC 65 Wethersfield Avenue Hartford, CT 06114-1190 (860) 249-1361 (860) 249-7665 (FAX) [email protected]

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