Free Motion to Amend/Correct - District Court of Connecticut - Connecticut

Case 3:01-cv-01877-MRK

Document 46

Filed 02/20/2004

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UNITED STATES DISTRICT COURT DISTRICT OF CONNECTICUT

DANIEL G. MALCHMAN v. CITY OF NORWICH

: : : : :

NO.: 3:01CV01877 (MRK)

FEBRUARY 17, 2004

MOTION TO MODIFY THE SCHEDULING ORDER

Pursuant to Fed. R. Civ. P. 16(b) and Local Rule 9(b), the defendant, City of Norwich, hereby requests that the case management deadlines set forth in the Scheduling Order approved by the Court be modified in accordance with the deadlines set forth below. This matter has been subject to the Legion stay which concluded on January 28, 2004. In order to move this case forward, the parties have jointly agreed to the following deadlines going forward: 1. All discovery, including the depositions of expert witnesses pursuant to Fed. R. Civ. P. 26(b)(4) will be commenced with immediately and be completed by September 1, 2004. 2. Plaintiff will designate all trial experts and provide opposing counsel with reports from retained experts pursuant to Federal Rule of Civil Procedure 26(a)(2) by June 1, 2004, a date not later than three months before the deadline for completing all discovery. Depositions of any such experts will be completed by July 1, 2004, a date not later than three months before the deadline for completing all discovery.

Case 3:01-cv-01877-MRK

Document 46

Filed 02/20/2004

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3.

Defendants will designate all trial experts and provide opposing counsel with reports from retained experts pursuant to Federal Rule of Civil Procedure by August 1, 2004, a date not later than one month before the deadline for completing all discovery. Depositions of such experts will be completed by September 1, 2004, a date not later than discovery cut off date.

4.

On April 1, 2004 a damage analysis will be provided by any party who has a claim or counterclaim for damages by April 1, 2004.

5. 6.

Dispositive motions will be filed on or before October 1, 2004. The joint trial memorandum required by the standing order on trial memorandum in civil cases will be filed by November 1, 2004 or thirty (30) days after this Court rules on any dispositive motion, which ever is later.

7.

This case will be ready for trial by December 1, 2004 or thirty (30) days after the joint trial memorandum is filed, which ever is later.

Pursuant to Local Rule 9(b)(2), the undersigned has contacted counsel for the plaintiff, Daniel G. Malchman, and has been advised that the plaintiff has no objection to the granting of this motion.

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Case 3:01-cv-01877-MRK

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Filed 02/20/2004

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WHEREFORE, the defendant, City of Norwich, respectfully requests that its motion be granted, and that the case management deadlines be modified in accordance with the date set forth herein. THE DEFENDANT, CITY OF NORWICH

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) [email protected]

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Case 3:01-cv-01877-MRK

Document 46

Filed 02/20/2004

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CERTIFICATION This is to certify that a copy of the foregoing has been sent to all counsel of record this 17th day of February, 2004.

John R. Williams, Esquire Williams & Pattis, LLC 51 Elm Street, Suite 409 New Haven, CT 06510 Michael E. Driscoll, Esquire Brown, Jacobson, P.C. 22 Courthouse Square P.O. Box 391 Norwich, CT 06360-0391 John M. Massameno, Esquire Office of the Chief State's Attorney 300 Corporate Place Rocky Hill, CT 06067 /s/ John J. Radshaw, III John J. Radshaw, III

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