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

Case 3:01-cv-02374-CFD

Document 78

Filed 01/19/2005

Page 1 of 2

UNITED STATES DISTRICT COURT DISTRICT OF CONNECTICUT

EDWARD BROWN, ET AL v. TOWN OF STONINGTON, ET AL

: : : : :

NO.: 3:01CV2374 (CFD)

JANUARY 19, 2005

DEFENDANTS' MOTION TO MODIFY SCHEDULING ORDER

The defendants, TOWN OF STONINGTON, DAVID ERSKINE, JERRY DESMOND, RAYMOND CURIOSO, JOHN CARR, and MICHAEL PECKHAM hereby move for a modification of the scheduling order as set forth below. The modification of the scheduling order is necessary for the plaintiff to conduct additional discovery insofar as his counsel has withdrawn from representing him and he has not been able to obtain counsel on his own and to allow for a renewal of the defendants' dispositive motion. The defendants move that the scheduling order is modified as follows: 1. 2. 3. Completion of discovery Dispositive motions Joint trial memorandum March 15, 2005; April 18, 2005; May 16, 2005 or sixty (60) days after the decision on any dispositive motion; and 4. Trial ready June 2005.

Counsel for the defendants has contacted the plaintiff pro se, EDWARD BROWN, who does not agree with these dates. Plaintiff BROWN has not retained an

Case 3:01-cv-02374-CFD

Document 78

Filed 01/19/2005

Page 2 of 2

attorney, does not know how long it will take to retain an attorney and cannot agree to any modifications until he has retained an attorney. Counsel for the defendant spoke with Attorney Phillips, counsel for plaintiff JEFFERY MENARD who has authorized the undersigned to represent that MENARD has settled with the defendants and will file a stipulation for dismissal of his claims shortly WHEREFORE, the defendants pray that their motion is granted. THE DEFENDANTS, TOWN OF STONINGTON, DAVID ERSKINE, JERRY DESMOND, RAYMOND CURIOSO, JOHN CARR AND MICHAEL PECKHAM

/s/John J. Radshaw, III_____ John J. Radshaw, III, ct19882 HOWD & LUDORF, LLC 65 Wethersfield Avenue Hartford, CT 06114-1190 (860) 249-1361 (860) 249-7665 (Fax) [email protected] CERTIFICATION This is to certify that a copy of the foregoing has been sent, handling charges prepaid, via U. S. Mail, to the following pro se parties and counsel of record this 19th day of January, 2005. R. Edward Phillips, Esquire Edward Brown Law Office of Warren Miller 4 Marlene Drive One Union Plaza, 2nd floor Ledyard, CT 06339 P.O. Box 116 New London, CT 06320

/s/John J. Radshaw, III John J. Radshaw, III

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