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

Case 3:01-cv-01927-WWE

Document 76

Filed 02/21/2006

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UNITED STATES DISTRICT COURT DISTRICT OF CONNECTICUT LISA CHARETTE Plaintiff v. : : : : : CIVIL NO. 3:01CV1927(WWE)

STATE OF CONNECTICUT DEPARTMENT OF SOCIAL SERVICES, ET AL. Defendants :

February 21, 2006

JOINT MOTION FOR EXTENSION OF TIME MODIFYING SCHEDULING ORDER COMES NOW the defendants, State of Connecticut Department of Social Services, Rudolph Jones, Ronald Georgetti, John Galiette, John Halliday and Brian Merbaum, through counsel and with concurrence of plaintiff's counsel, and requests an extension of time of one hundred and twenty (120) days, resetting the discovery deadline to and including August 3, 2006 and the deadline for dispositive motions to and including September 3, 2006. In support of their motion, the defendants, through counsel represent as follows: 1. The current Scheduling Order has set the discovery deadline for April 3, 2006 and

the deadline for dispositive motion for May 3, 2006 (Doc. # 73, January 26, 2006). 2. A telephonic status conference was held with the Honorable United States District

Court Judge Warren W. Eginton on Tuesday morning, February 21, 2006. The plaintiff was represented by Katrena Engstrom of the law firm of Williams & Associates, LLC, and the defendants were represented by the undersigned, Assistant Attorney General Joseph A. Jordano. 3. Plaintiff's counsel represented that the plaintiff was too traumatized to be deposed

and would be unable to attend a deposition noticed for February 28, 2006. The defendants have

Case 3:01-cv-01927-WWE

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Filed 02/21/2006

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noticed the deposition of the plaintiff on several occasions but have not been able to depose the plaintiff to date. 4. The Court informed plaintiff's counsel that until and unless plaintiff was

medically able to be deposed, his inclination was to check the proper procedure for administratively dismissing the case without prejudice until such time as the plaintiff was able to be deposed and participate in the instant matter. The Court noted that the defendants had the right to depose the plaintiff and the plaintiff has to be well enough to testify at trial, if necessary, so the matter cannot proceed. 5. The Court directed the parties to file a motion for extension of time regarding the

deadlines in the instant matter until such time it could be addressed administratively. The instant motion adheres to the Court's suggestive plan of action. 6. Plaintiff's counsel, Ms. Engstrom, indicated that any motion for extension of the

deadlines should be made jointly.

WHEREFORE, the defendants, with the concurrence of plaintiff's counsel, respectfully requests an extension of time of one hundred and twenty (120) days, extending the discovery deadline to and including August 3, 2006 and the deadline for filing of dispositive motion to September 3, 2006 pending the Court administratively dismissing the instant matter.

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Case 3:01-cv-01927-WWE

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Filed 02/21/2006

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DEFENDANTS RICHARD BLUMENTHAL ATTORNEY GENERAL

By: ________________________ Joseph A. Jordano Assistant Attorney General 55 Elm Street, P.O. Box 120 Hartford, CT 06141-0120 Tel: (860) 808-5340 Fax: (860) 808-5383 Email: [email protected] Federal Bar # ct21487

CERTIFICATION I hereby certify that on February 21, 2006 a copy of the foregoing Joint Motion for Extension of Time Modifying Scheduling Order was filed electronically. Notice of this filing was sent by e-mail to all parties by operation of the Court's electronic filing system. Parties may access this filing through the Court's system. /s/_Joseph A. Jordano_____________ Joseph A. Jordano (# ct21487) Assistant Attorney General 55 Elm Street, P.O. Box 120 Hartford, CT 06141-0120 Tel.: (860) 808-5340 Fax: (860) 808-5383 E-mail: [email protected]

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