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

Case 3:01-cv-02394-WIG

Document 53

Filed 04/26/2004

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UNITED STATES DISTRICT COURT DISTRICT OF CONNECTICUT

WILLIAM DZIEKANOWSKI MAUREEN TRAVERS v. THE ARROW LINE, INC. LEONARDO PEREZ

: : : : : : :

NO.: 3:01CV2394 (WIG)

APRIL 22, 2004

MOTION TO MODIFY ORDERS RE: TRIAL BRIEFS AND PRETRIAL CONFERENCE DATES Pursuant to Federal Rule 16 and the District of Connecticut Standing Order regarding trial memoranda in civil cases undersigned counsel requests that the court amend the orders that were previously entered in connection with the trial memorandum and pretrial conference in this matter. Prior to the time that this matter was transferred to Judge Garfinkel, Judge Kravitz had issued orders that trial briefs were to be filed with the court on April 23, 2004 and that a pretrial conference was to be held on April 28, 2004. Both of those orders were in connection with a trial date of May 4, 2004. The defendants request that the date for said events be extended based on the fact that evidence in this matter is not scheduled to commence until June 28, 2004. Therefore, no prejudice to any party nor trial delay would ensue if the dates for the

ORAL ARGUMENT IS NOT REQUESTED

Case 3:01-cv-02394-WIG

Document 53

Filed 04/26/2004

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submission of the trial memorandum and pretrial conference were extended. Additionally, based on information and belief plaintiffs' counsel is on vacation the week of April 19 - 23 and thus it is not possible that the parties may jointly prepare the trial memorandum. WHEREFORE, based on the foregoing the defendants respectfully request that the court grant its motion to amend the scheduling order.

DEFENDANTS, THE ARROW LINE, INC. and LEONARDO PEREZ

By_______________________________ Paul Erickson Howd & Ludorf 65 Wethersfield Avenue Hartford, CT 06114 (860) 249-1361 ct21398

Case 3:01-cv-02394-WIG

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Filed 04/26/2004

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CERTIFICATION This is to certify that a copy of the foregoing has been sent, handling charges prepaid, via fax and U.S. mail to the following counsel of record this 22nd day of April, 2004. Adele R. Jacobs, Esquire 1375 Kings Highway East, Ste. 425 Fairfield, CT 06824

_________________________________ Paul Erickson Howd & Ludorf 65 Wethersfield Avenue Hartford, CT 06114 (860) 249-1361