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

_ Case 3:03-cv—0O9(35DJS Document 20 Filed 12/29!§003 Paget of 3
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UNITED STATES DISTRICT count 1.i.i?·_.? I
DISTRICT OF CONNECTICUT " “"
; CIVIL ACTION No; sbs cvsrs (DJS)
Plaintiff :
VS. `
STATE OF CONNECTICUT, I
DEPARTMENT OF TRANSPORTATION: )
Defendant : DECEMBER 26, 2003
MOTION FOR MODIFICATION OF SCHEDULING ORDER
The Plaintiff in the above-entitled action hereby move to modify the scheduling order
previously issued in this case for the purpose of extending the deadline for disclosure of
Plaintiffs expert witness on damages. In support of this motion, the undersigned states:
1) On June 23, 2003, Plaintiff filed a First Request for Disclosure and Production F
seeking, among other things, documents necessary to make a caluclation of damages in thi
case. Although Defendant responded to this Request by making said records available for
review on September 25, 2003, and although Plaintiffs counsel on that date identified
documents to be copied in accordance with Defendants instructions, she has only recently
received documents relevant to the issue of damages.
3) Said information has now been reviewed and compiled by the undersigned, and
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must be reviewed by Plaintiff’s expert in order to prepare an expert disclosure and report. I
4) At present, Plaintiff is required to disclose her expert on or before January 2, 2004. ¤
Plaintiff now seeks and additional 14 days to complete that disclosure, until January 16, 20 4. I
Extending this deadline for a period of 14 days will not affect the other deadlines set in this I
case, nor the readiness of this case for trial.
5) The undersigned represents she has attempted to contact Assistant Attorney
General Steven Courtney, who represents the Defendant in this matter, but has been unabl tc
ascertain his position as to this request.
. 6) This is the second motion requesting an extension of this deadline.
WHEREFORE, the Plaintiff requests that the scheduling order be altered to provide s I
follows: I
Plaintiff will designate all trial experts and provide opposing counsel with reports fro
retained experts by January 14, 2004.
PLAINTIFF
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I By: ,.-·"
Kathleen Idergill [
Beck & Eldergill, P.C. I
447 Center Street
Manchester, CT 06040
(860) 646-5606
Fed Bar No: ct00024
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BEc1 447 CENTER STREET · MANCEIESTER, CT 06040 • (S60)646-5606 • juR1s No. 02702
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y Case 3:03-cv—0O9g2.RDJS Document 20 Filed 12/29§003 Page 3 of 3
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CERTIFICATION I
I hereby certify that a copy of the foregoing has been mailed this 26** day of
December 2003, to the following parties:
Stephen J. Courtney
Assistant Attorney General
Attorney GeneraI's Office
55 Elm Street
P.O. Box 120
Hartford, CT 06141-0120 ;~;.¤>
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Kathleen Eldergill
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Bizcx AN1L`;“II;°.l(;II;II;éIIILL, P.C. `
447 CENTER Swiznnt • MANci1ns1nR,(lT06040 • (860)646-5606 • jums N0. 02702.