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

Case 3:01-cv-01927-WWE

Document 95

Filed 08/18/2006

Page 1 of 2

UNITED STATES DISTRICT COURT DISTRICT OF CONNECTICUT LISA A. CHARETTE VS. : NO. 3:01CV1927(WWE) AUGUST 16, 2006

DEPT. OF SOCIAL SERVICES, ET AL. :

MOTION TO EXTEND DEADLINES The plaintiff, LISA CHARETTE, respectfully moves for an extension of deadlines in this case for the following reasons: 1. Defendants' counsel has commenced the plaintiff's deposition but has not yet completed it. 2. The deposition is taking place at the office of the plaintiff's therapist, who is not available again until September 12 due to vacation and work related matters; 3. Defendants' counsel does not oppose an extension of the deadlines which are proposed to be modified as set forth below: (a) All discovery, including depositions of expert witnesses, will completed by November 30, 2006. (b) Dispositive motions will be filed on or before January 6, 2007. (c) The joint trial memorandum will be filed by February 12,

Case 3:01-cv-01927-WWE

Document 95

Filed 08/18/2006

Page 2 of 2

2007, or (30) thirty days after this court rules on any summary judgment motion filed by the defendants, whichever is later. 4. Defendants' counsel joins with plaintiff's counsel in this motion.

THE PLAINTIFF

BY

/s/ KATRENA ENGSTROM (ct09444) John R. Williams and Associates, LLC 51 Elm Street New Haven, CT 06510 (203) 562-9931 FAX: (203) 776-9494 E-Mail: [email protected] Her Attorney

CERTIFICATION OF SERVICE On the date above stated, a copy of the foregoing was filed electronically and served by mail on anyone unable to accept electronic filing. Notice of this filing will be sent by e-mail to all parties by operation of the Court's electronic filing system or by mail to anyone unable to accept electronic filing as indicated on the Notice of Electronic Filing. Parties may access this filing through the Court's CM/ECF System.

/s/ KATRENA ENGSTROM