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

Case 3:01-cv-01979-WWE

Document 48

Filed 05/27/2004

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UNITED STATES DISTRICT COURT DISTRICT OF CONNECTICUT

KARL HOGFELDT

: : v. : : OLD SAYBROOK POLICE DEPARTMENT : SERGEANT DONALD HULL; PATROLMAN : DAVID PERRROTTI; PATROLMAN CHRIS : DEMARCO; PATROLMAN JAY RANKIN; : EACH INDIVIDUALLY AND AS POLICE : OFFICERS AND MEMBERS OF THE OLD : SAYBROOK POLICE DEPARTMENT; AND : THE TOWN OF OLD SAYBROOK :

NO.: 3:01CV1979 (WWE)

MAY 25, 2004

MOTION OF EXTENSION OF TIME TO DISCLOSE EXPERT WITNESSES The defendants, Town of Old Saybrook Police Department, Sergeant Donald Hull, Patrolman David Perrrotti, Patrolman Chris DeMarco, Patrolman Jay Rankin and the Town of Old Saybrook, hereby move for an extension of time in which to disclose experts on their behalf until June 30, 2004. In support of this motion, the defendants offer as follows: 1. Defendants' expert has been waylaid by the springtime graduation season and cannot reasonably complete his report and documentation by June 2, 2004. ORAL ARGUMENT IS NOT REQUESTED

Case 3:01-cv-01979-WWE

Document 48

Filed 05/27/2004

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Therefore, the defendants submit that an extension of time until June 30, 2004 is fair, just and reasonable under the circumstances. WHEREFORE, the defendants pray that the motion is granted.

DEFENDANTS, OLD SAYBROOK POLICE DEPARTMENT, SERGEANT DONALD HULL, PATROLMAN DAVID PERRROTTI, PATROLMAN CHRIS DEMARCO, PATROLMAN JAY RANKIN AND THE TOWN OF OLD SAYBROOK

By/s/John J. Radshaw, III John J. Radshaw, III ct19882 Howd & Ludorf 65 Wethersfield Avenue Hartford, CT 06114 (860) 249-1361 (860) 249-7665 (Fax) E-mail: [email protected]

Case 3:01-cv-01979-WWE

Document 48

Filed 05/27/2004

Page 3 of 3

CERTIFICATION This is to certify that a copy of the foregoing has been sent, handling charges prepaid, via U.S. mail to the following counsel of record this 25th day of May, 2004. Bruce E. Newman, Esquire Newman, Creed & Associates 99 North Street, Route 6 P.O. Box 575 Bristol, CT 06011 A. Paul Spinella, Esquire Spinella & Associates One Lewis Street Hartford, CT 06103

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