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

Case 3:01-cv-02137-SRU

Document 36

Filed 04/30/2004

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UNITED STATES DISTRICT COURT DISTRICT OF CONNECTICUT SHAKUNTALA SCHNIRRING, Plaintiff, v. METRO-NORTH RAILROAD COMPANY, v. Defendant/Third-Party Plaintiff, April 29, 2004 Third-Party Defendant JOINT MOTION FOR EXTENSION OF TIME TO FILE JOINT TRIAL MEMORANDUM AND APPEAR FOR TRIAL CALENDAR CALL The parties and their attorneys hereby respectfully move jointly for an extension of time to file the Joint Trial Memorandum and appear for a Trial Calendar Call in the above-captioned action based on the following: 1. This is the parties' first motion to extend the JTM Civil Action No.: 301 CV 02137 SRU

STEADFAST INSURANCE COMPANY,

deadline and to postpone calendar call since Steadfast Insurance Company was joined as a Third-Party Defendant. A prior motion for an extension of the instant deadlines was filed so that Steadfast could be joined and a settlement conference could be held with all parties necessary to discuss meaningful settlement. 2. On April 9, 2004, new counsel, Landman Corsi Ballaine &

Ford, P.C., appeared as substituted counsel for defendant/ thirdparty plaintiff Metro-North Railroad Company.

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Case 3:01-cv-02137-SRU

Document 36

Filed 04/30/2004

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3.

On April 26, 2004, Magistrate Judge Garfinkel held a

conference call and directed all parties to appear for a settlement conference on May 14, 2004. 4. The Court's current deadline for filing the Joint Trial

Memorandum is April 30, 2004 and there is a scheduled Trial Calendar Call for May 7, 2004. 5. All parties consent and join in this request. it is respectfully requested that the Court,

WHEREFORE,

pursuant to Local Rule 7(b) extend the time for the parties to file the Joint Trial Memorandum and appear for the Trial Calendar Call until a later date, if necessary, after the settlement conference scheduled before Magistrate Garfinkel on May 14, 2004. Respectfully submitted, On Consent Of All Parties By: FOR THE DEFENDANT/ THIRD-PARTY PLAINTIFF Metro-North Railroad Company

Brian M. Molinari (ct 21294) LANDMAN CORSI BALLAINE & FORD, P.C. 120 Broadway - 27th Floor New York, New York 10271-0079 Tel (212) 238-4800 Fax (212) 238-4848 E-Mail: [email protected]

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Case 3:01-cv-02137-SRU

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Filed 04/30/2004

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CERTIFICATION OF SERVICE This is to certify that a copy of the foregoing was mailed to all parties on April 29, 2004: To: Scott E. Perry, Esq. Cahill & Goetsch, P.C. 43 Trumbull Street New Haven, CT 06510 Nancy Lyness, Esq. White Fleischner & Fino, LLP 140 Broadway New York, NY 10005

Brian M. Molinari

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