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

Case 3:01-cv-01913-DJS

Document 83

Filed 09/11/2006

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UNITED STATES DISTRICT COURT DISTRICT OF CONNECTICUT HOWARD JOHN GOMBERT Plaintiff, v. LARRY LYNCH and WILLIAM KAMINSKI Defendants : : : : : : :

Civil Action No. 3:01 CV 1913 (DJS)

September 11, 2006

PLAINTIFF'S UNOPPOSED MOTION FOR EXTENSION OF TIME Pursuant to Local Rule 7(b), the Plaintiff Howard John Gombert ("Mr. Gombert") respectfully moves for an extension of time of thirty (30) days, up to and including November 13, 2006, within which to file the Joint Trial Memorandum. In support of this Motion, the undersigned represents the following: 1. Bingham McCutchen LLP ("Bingham") was just recently appointed as pro bono

counsel for Mr. Gombert in this matter at the request of this Court after Mr. Gombert's claims survived summary judgment in part. The additional time requested is necessary to allow the undersigned and other counsel at Bingham to complete needed additional discovery to prepare this case for trial (including the Defendants' depositions which have never been taken) and to review all materials in this case, including, without limitation, pleadings, motions, discovery, depositions and rulings, and to communicate with Defendants' counsel regarding the Joint Trial Memorandum.

ORAL ARGUMENT NOT REQUESTED TESTIMONY NOT REQUIRED
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Case 3:01-cv-01913-DJS

Document 83

Filed 09/11/2006

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2.

A pretrial conference has not been scheduled for this case and it has not been

assigned for jury selection or a trial date. 3. Counsel for the Defendants has been contacted and stated that he has no objection

to the granting of this Motion. 4. 5. This is Mr. Gombert's first request for an extension of time. The current deadline for filing the Joint Trial Memorandum is October 13, 2006.

If the Court grants this Motion, the Joint Trial Memorandum would be due on November 13, 2006. WHEREFORE, Mr. Gombert respectfully moves for an extension of up to and including November 13, 2006 within which to file the Joint Trial Memorandum. THE PLAINTIFF, HOWARD JOHN GOMBERT

By: /s/ Sara R. Simeonidis________________ Ben M. Krowicki [ct06153] Kate K. Simon [ct23489] Sara R. Simeonidis [ct25566] Brian R. Hole [ct26608] Meghan Freed Pelletier [ct26673] BINGHAM McCUTCHEN LLP One State Street Hartford, CT 06103 Tel: (860) 240-2700 Fax: (860) 240-2818 His Attorneys

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Case 3:01-cv-01913-DJS

Document 83

Filed 09/11/2006

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CERTIFICATION I hereby certify that a true and accurate copy of the foregoing was sent via the Court's electronic notification system or by first class U.S. mail, postage prepaid, on this 11th day of September, 2006, to the following counsel of record: James N. Tallberg, Esq. Karsten & Dorman, LLC 29 South Main Street West Hartford, CT 06107

/s/ Sara R. Simeonidis_____________________ Sara R. Simeonidis

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