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

Case 3:01-cv-02313-RNC

Document 114

Filed 12/30/2003

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UNITED STATES DISTRICT COURT DISTRICT OF CONNECTICUT CARLEEN AHERN v. TRANS UNION LLC ZALE CORPORATION TRANS UNION LLC=S UNOPPOSED MOTION TO ADJOURN SETTLEMENT CONFERENCE Trans Union respectfully requests that the December 31, 2003 Settlement Conference be adjourned to a date during the first two weeks of January, 2004 and avers the following in support of the request: 1. This case was originally scheduled for trial in the January Term, with jury selection 301cv02313 (DJS) DATED: DECEMBER 24, 2003

on January 6, 2004. On December 10, 2003, the District Judge referred this matter to this Court for a settlement conference only, which was set for December 31, 2003. 2. The final pretrial was held on Monday, December 22, 2003. Because of the various

pretrial motions and other matters raised, the trial was adjourned from January until the February Term. 3. Because the trial is no longer imminent, Trans Union respectfully requests that the

settlement conference be moved to January 7, 8 or a convenient date during the week of January 12. Plaintiff has agreed to this request. (Trans Union's corporate representative has a federal court settlement conference in Minnesota on January 6, 2003.) 4. Trans Union's corporate representative, Pat Norris, Esquire, is based in Chicago,

Illinois. Ms. Norris participated in the original May 2002 settlement conference in this action and is very familiar with the case. Because of the heightened terror alert, Trans Union respectfully submits

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that air travel in and out of Chicago's airports will be very difficult on New Year's Eve. In addition, the heightened alert will likely impact travel for Trans Union's litigation counsel, Bruce Luckman, because of train and/or traffic conditions traveling from Philadelphia to Hartford through New York City during New Year's Eve day.) 5. In the alternative, if the settlement conference is not adjourned, Trans Union requests

permission for Ms. Norris to participate via telephone during the conference. Ms. Norris is very familiar with the claim and the fact that she is not physically present will not impact you ability to make settlement determinations. This is particularly true because she has already participated in person in the first (unsuccessful) mediation of this action with this Court. CONCLUSION 6. Counsel for Trans Union has conferred with counsel for Plaintiff, and Plaintiff does

not object to the request to adjourn the conference. (paras. 1 through 4 above) 7. For all the foregoing reasons and concerns, Trans Union respectfully requests that the

settlement conference be re-scheduled to the either of the first two weeks of January 2004. Respectfully Submitted, _________________________________ BRUCE S. LUCKMAN (ct 10830) SATZBERG, TRICHON, KOGAN & WERTHEIMER, P.C. 1818 Market St., 30th Floor Philadelphia, PA 19103 (215) 575-7600; Fax: (215) 575-688 Local Counsel: Ira W. Bloom, Esq. (ct 07629) WAKE, SEE, DIMES & BRYNICZKA 27 Imperial Ave., P.O. Box 777 Westport, CT 06881-0777 (203) 227-9545; Fax: (203) 226-1641 email: [email protected] Counsel for Defendant, Trans Union LLC

Case 3:01-cv-02313-RNC

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UNITED STATES DISTRICT COURT DISTRICT OF CONNECTICUT

CARLEEN AHERN 301cv02313 (DJS) v. TRANS UNION LLC ZALE CORPORATION

CERTIFICATE OF SERVICE Bruce S. Luckman, Esq., hereby certifies that he caused a true and correct copy of the foregoing Motion to Adjourn to be sent on this date, via FedEx, postage prepaid, to the following: Joanne S. Faulkner, Esq. 123 Avon St. New Haven, CT 06511-2422 (203) 772-0395 Counsel for Plaintiff _________________________________ BRUCE S. LUCKMAN

DATED:

December 24, 2003