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

Case 3:00-cv-00973-AHN Document 85 Filed 02/1 1/2005 Page 1 of 3 I
UNITED STATES DISTRICT COURT
DISTRICT OF CONNECTICUT ZIIII5 FEB I I A IO: 01
C.A. NO.: 3:00 CV 0973 (AHS) F)
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TIMOTHY HAYES, ) `
Plaintiff] )
)
v. )
) r
COMPASS GROUP USA, INC., ) I E
d/b/a EUREST DINING SERVICES )
·~ and CARY ORLANDI, )
)
Defendants. )
_______._.__> I
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· JOINT MOTION T0 ENLARGE TIME FOR FILING DOCUMENTS IN
ACCORDANCE WITH PRE-TRIAL ORDER I
Pursuant to Local Rule 7.l(b), the parties jointly request that the corut extend by several
days, until Monday, February I4, 2005, the deadline for filing:
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(I) Proposed Jury Instructions,
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(2) The Joint Statement of the Case (including any motions in limine), and I I
(3) Supplemental Witness Lists. I I
This extension will not affect the court’s (or parties’) preparedness for trial, which is I
scheduled to begin on Friday, February 18, 2005. Before now, neither party has requested any I I
extension of time under the Pre-Trial Order. Although the parties have made cooperative, good I I
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faith efforts to confer and collaborate on their pre—trial submissions, counsel need additional time
within which to complete their efforts in advance of trial.
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WHEREFORE, the parties ask that the court extend until February 14 the deadline for
proposed jury instructions, a Joint Statement of the Case and supplemental witness lists.
ioooszmnocrzi I

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Case 3:00-cv-00973-AHN Document 85‘ Filed O2/11/2005 Page 2 of 3 Q
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Tmotrm HAYES, coM1=·ASS oaow USA, mc. AND 1 ~
CARY ORLANDI, 1
By his By their attorneys,
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Stephe c lene , Fed. Bar # CT06181 Christophe A. Kenney, ed. Bar #: CT250l7
McEleney .1 Mc rail, LLC Margaret H. Paget, Fed. Bar #: CT25016
363 Main tree Sherin and Loden LLP
Hartford, T h 106 101 Federal Street I
Boston, MA 02110
(Sm 646-2000 R
Dated: February 10, 2005 Q
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Case 3:00-cv-00973-AHN Document 85 Filed 02/11/2005 Page 3 of 3 I
CERTIFICATION
I HEREBY CERTIFY, that a copy ofthe Joint Motion to Enlarge Time for Filing Documents I
in Acccrdance with Pre-Trial Order was sent overnight mail on this the 10"‘ day of February, 2005 i
to the following counsel of record: I
Christopher Kenney, Esq. I
Margaret Paget, Esq. I
Sherin and Lodgen LLP g
100 Summer Street ’ `
Boston, MA 02110 I
And mailed, iirst class mail, postage prepaid on this the 10'“ day of February, 2005 to: E
Lawrence Peikes, Esq.
Wiggin and Dana LLP I
400 Atlantic Street I
Stamford, CT 06901 I
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Fred Frangie, Esq.
Robert Fortgang & Associates
573 Hopmeadow Street
Simsbury, CT 06070 ,_,. .- ·· I
An l
Stephen '. y, Esq. I
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