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

Case 3:01-cv-01979-WWE

Document 41

Filed 04/16/2004

Page 1 of 3

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)

APRIL 13, 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 2, 2004. In support of this motion, the defendants offer as follows: 1. The plaintiff made a partial disclosure of experts in October and sought an extension of time in which to do so; 2. The plaintiff's expert disclosures did not comply with Federal Civil

ORAL ARGUMENT IS NOT REQUESTED

Case 3:01-cv-01979-WWE

Document 41

Filed 04/16/2004

Page 2 of 3

Procedure 26 and their reports have arrived in over the following months; 3. No modification was made to the scheduling order to allow the defendants to disclose said experts; 4. Accordingly, it is fair just and reasonable to allow the defendant's an extension of time in which to review the plaintiff's disclosures and reports and retain their own experts. Therefore, the defendants submit that an extension of time until June 2, 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 41

Filed 04/16/2004

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 13th day of April, 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