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

Case 3:01-cv-01927-WWE

Document 64

Filed 09/30/2005

Page 1 of 3

UNITED STATES DISTRICT COURT DISTRICT OF CONNECTICUT

LISA CHARETTE, Plaintiff,

v.

: : : : : :

CIVIL DOCKET NO. 3:01CV1927(WWE)

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

SEPTEMBER 29, 2005

MOTION TO RE-OPEN SCHEDULING ORDER AND RESET PRETRIAL DEADLINES The defendants, State of Connecticut, Department of Social Services, et al., respectfully request the Court to re-open the Scheduling Order and reset pre-trial deadlines as set forth below. In support hereof, the defendants represent the following: 1. Because of a conflict that has arisen with the defendants, the undersigned will be withdrawing her appearance in the above-referenced matter and as a result, will necessitate this matter being re-assigned. 2. The undersigned further represents that the modification of the existing Scheduling order is necessary to afford the newly assigned Assistant Attorney General ample time/opportunity to review and familiarize him/herself with the abundance of material and documents so that he/she will be adequately prepared to represent and vigorously defend the defendants in this matter. 3. The undersigned requests the extension of the pre-trial deadlines as follows:

Case 3:01-cv-01927-WWE

Document 64

Filed 09/30/2005

Page 2 of 3

a. b. c.

Discovery, including deposition(s) will be completed by February 1, 2006; Dispositive motions will be filed on or before March 15, 2006; Joint trial memorandum will be sixty (60) days after the close of discovery in this matter or after this Court's ruling or any dispositive motions which may be filed, whichever is later.

This case will be ready for trial thirty (30) days after submission of the Parties' Joint Trial Memorandum. The undersigned further represents that she has contacted plaintiff's counsel, Attorney John Williams, and represents that he has no objection to the undersigned's Motion. WHEREFORE, the undersigned respectfully requests that this Court re-open the Scheduling Order and extend the pre-trial deadlines as set forth above so that the new discovery deadline will become February 1, 2006, with dispositive motions due by March 1, 2006.

Case 3:01-cv-01927-WWE

Document 64

Filed 09/30/2005

Page 3 of 3

STATE OF CONNECTICUT, DEPARTMENT OF SOCIAL SERVICES, RICHARD BLUMENTHAL ATTORNEY GENERAL

BY:

__________________________ Tammy D. Geathers Assistant Attorney General Federal Bar No. Ct22426 55 Elm Street - P.O. Box 120 Hartford, CT 06141-0120 Tel: (860) 808-5340 Fax: (860) 808-5383 Email: [email protected]

CERTIFICATION

I hereby certify that the foregoing Motion To Re-Open Scheduling Order and Re-Set Pretrial Deadlines was mailed, first class postage prepaid, this 29th day of September, 2005 to:

John R. Williams, Esq. Williams and Associates, LLC 51 Elm Street, Suite #409 New Haven, CT 06510

________________________ Tammy D. Geathers Assistant Attorney General