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

Case 3:03-cv-00596-JBA

Document 63

Filed 02/02/2004

Page 1 of 3

UNITED STATES DISTRICT COURT DISTRICT OF CONNECTICUT TOM JAMES COMPANY, Plaintiff, V. TRACE APPAREL LLC and J. TRACY GREEN, Defendants. : : : : : : : : : : CIVIL ACTION NO. 303 CV 0596 (JBA)

FEBRUARY 2, 2004

MOTION FOR EXTENSION OF TIME ON CONSENT Pursuant to Rule 7(b) of the Local Civil Rules of the United States District Court for the District of Connecticut, the plaintiff, Tom James Company ("Tom James"), hereby moves this Court for an extension of time of fourteen (14) days in which to disclose an expert and serve an expert report, up to and including February 16, 2004. As good cause for the requested extension of time, Tom James submits that additional time is necessary in order to fully and properly assess Tom James' damages. As discovery is ongoing, Tom James has yet to receive complete financial information from the defendants necessary to adequately analyze Tom James' damages. Tom James needs the additional time requested in order to obtain additional relevant documents and properly evaluate the extent of its damages resulting from the defendants' conduct at issue in this action. This is Tom James' first motion for extension of time regarding this matter. Counsel for Defendant has consented to the requested extension of time.

One Goodwin Square 225 Asylum Street Hartford, CT 06103

HALLORAN & SAGE LLP

Phone (860) 522-6103 Fax (860) 548-0006 Juris No. 26105

Case 3:03-cv-00596-JBA

Document 63

Filed 02/02/2004

Page 2 of 3

WHEREFORE, the plaintiff, Tom James Company, respectfully requests that the Court grant its Motion for Extension of Time on Consent, dated February 2, 2004, and extend the deadline to disclose an expert and expert report, up to and including February 16, 2004.

Dated: February 2, 2004 Hartford, Connecticut

RESPECTFULLY SUBMITTED, THE PLAINTIFF TOM JAMES COMPANY

By:________________________ Thomas J. Finn Federal Bar No.: ct 20929 Paula Cruz Cedillo Federal Bar No.: ct 23485 HALLORAN & SAGE LLP One Goodwin Square 225 Asylum Street Hartford, Connecticut 06103 (860) 522-6103

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One Goodwin Square 225 Asylum Street Hartford, CT 06103

HALLORAN & SAGE LLP

Phone (860) 522-6103 Fax (860) 548-0006 Juris No. 26105

Case 3:03-cv-00596-JBA

Document 63

Filed 02/02/2004

Page 3 of 3

CERTIFICATION This is to certify that on this 2nd day of February, 2004, a copy of the foregoing was either mailed, postage prepaid, or hand-delivered to:

Thomas A. Rouse, Esq. Peter S. Olson, Esq. Pullman & Comley, LLC 850 Main Street P.O. Box 7006 Bridgeport, Connecticut 06601-7006 Attorneys for Defendants

__________________________ Thomas J. Finn

510551

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One Goodwin Square 225 Asylum Street Hartford, CT 06103

HALLORAN & SAGE LLP

Phone (860) 522-6103 Fax (860) 548-0006 Juris No. 26105