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

Case 3:03-cv-01009-SRU Document 119 Filed 01/12/2006 Page 1 of 4
UNITED STATES DISTRICT COURT
DISTRICT OF CONNECTICUT
JOSEPH ATTIAS & HAIM ATTIAS : CIVIL ACTION NO.
: 3:03 CV 01009 (SRU)
VS. :
PATRONS MUTUAL INSURANCE
COMPANY OF CONNECTICUT : JANUARY 11, 2006
JOINT REQ QUEST FOR EXTENSION OF TIME TO FILE
PRETRIAL MEMORANDUM
Pursuant to an order issued by the Court, the Pretrial Memorandum in the above-
captioned matter is due on or before February 21, 2006. On December 28, 2005, the Court
issued an order granting the lplaintiffs’ disclosure of Louis Ranciato as an expert in this matter
and further has granted the defendant 60 days within which to depose Mr. Ranciato. Based
on this ruling, the defendant requests that the date for tiling the Pretrial Memorandum be
extended an additional 45 days so as to allow the defendant 30 days from the date of the
completion of Mr. Ranciato’s deposition to disclose an expert should the defendant deem it
necessary. The defendant sets forth the following in support of said motion:
1. This matter is scheduled for mediation before Magistrate Gartinkel on
February 7, 2006. Both parties are prepared to proceed on that date.
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Law 01'flcss or SKELLEY R01TNER P.C. I] 433 So. Main St., W. Hartford, CT 06110 D Phone: (860) 561-7077 Fax: (860) 561-7088
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Case 3:03-cv-01009-SRU Document 119 Filed 01/12/2006 Page 2 of 4
2. Both counsel for the defendant, J oe] J . Rottner and Heather Adams-Beman,
have been trying another matter before a jury in the Connecticut Superior Court since
November 9, 2005. Said trial is ongoing and is not likely to conclude evidence prior to the
end of the week of January 16, 2006.
3. Along with this motion, the defendant has requested dates for Mr. Ranciato’s
availability to appear at a deposition.
4. The defendant has reviewed the report prepared by Mr. Ranciato at the request
ofthe plaintiffs in this matter; however, without the deposition it is unclear whether he is
qualified to testify as to a number ofthe issues upon which he has rendered opinions.
Furthermore, it is unclear presently to the defendant whether it will require the services of an
expert to respond to opinions set forth by Mr. Ranciato.
This is the second request for an enlargement of time regarding the Pretrial
Memorandum. The deadline for the filing of the Pretrial Memorandum is now February 21,
2006. For the foregoing reasons, all parties hereby jointly request that the deadline for the
tiling of the Pretrial Memorandum be extended 45 days until April 7, 2006.
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Case 3:03-cv—O1009-SRU Document 119 Filed 01/12/2006 Page 3 of 4
Respectfully submitted,
DEFENDANT, PATRONS MUTUAL
INSURANCE COMPANY
gr ee‘·’11 1i
Heather J. Adams-Beman
Skelley Rettner P.C.
433 South Main Street, Suite 305
West Hartford, Connecticut 06110
Tel. (860) 561-7077
Fax (860) 561-7088
Federal Bar N0. ct2409l
PLAINTIFF S
By ( Q
Cheryl E. Heffe an
Farver & Heffernan
2842 Old Dixwell Avenue
Hamden, CT 06518
Tel. (203) 288-8266
Fax (203)288—4702
Federal Bar N0. ct 06473
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Law omeu ¤fSKELLE‘|' RDTTNER P.¤. [1 433 So. Main St., W. Hartford, CT 06110 [1 Phone: (860} 561-7077 Fax: (860} 561-7088
Juris N0. 58693

Case 3:03-cv—O1009-SRU Document 119 Filed O1/12/2006 Page 4 of 4
CERTIFICATION
I hereby certify that a copy of the above was mailed via U.S. Mail, postage prepaid,
on January 11, 2006, to the following counsel of record:
Attorney Cheryl E. Heffernan
Farver & Heffernan .
2842 Old Dixwell Avenue
Hamden, CT 06518
Tel. (203) 288-8266
jj { H/;____,
Heather J .-Adams-Beman
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Law Offices uf SKELLEY ROTTNER P.C. EI 433 S0. Main St., W. Hartford, CT 06110 II] Phone: {860) 5614077 Fax: {860) 561-7088
Juris N0. 58693