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

Case 3:03-cv—OO575—|\/IRK Document 12 Filed O2/23/2004 Page 1 of 3
UNITED STATES DISTRICT COURT
for the
DISTRICT OF CONNECTICUT
GLYNNIS SIMMONS CTVIL NO. 303CV00575 (MRR)
Plaintiff, :
v.
SHANER OPERATEANG CORP
Df}3/A RADISSON HOTEL & CONFERENCE 2
CENTER : February 20, 2004
Defendants. :
MOTION TO EXTEND DISCOVERY DEADLINE
Pursuant to the Federal Rules of Civil Procedure and Local Rule 9 of this Court,
the Defendants, Shaner Hotel Group Limited Partnership dfb/a the Radisson Hotel and
Conference Center, Connecticut, Shaner Operating Corp., General Partner, Operator and
Manager thereof incorrectly pled as Shaner Operating Corp. d/b/a Radisson Hotel & Conference
Center, respectfully requests a thirty (30) day extension of time, up to and including March 3l,
2004 to complete discovery and up to and including May 3, 2004 for tiling dispositive motions.
In support of this Motion, the Defendants provide the following:
1. Pursuant to the Report of Parties’ Planning Meeting, which was Approved
on June I3, 2003 the deadline for Discovery is March l, 2004 and the deadline for filing
dispositive motions is Aprii l, 2004..
2. The parties have exchanged written discovery The parties also have
attempted to schedule depositions-

Case 3:03-cv—OO575—l\/IRK Document 12 Filed O2/23/2004 Page 2 of 3
3. Due to trials and other commitments, counsel have been unable to
complete depositions.
4. Counsel for Defendant contacted Plaintiffs counsel regarding this motion
on February 19, 2004, and was informed he does not object to the granting of this motion.
5. No other motions for extension of time have been iiled with respect to
extending the discovery out—off and dispositive motion deadlines.
WHEREFORE, the Defendants tespectfully move for an extension of time, up to
and including March 31, 2004 to complete discovery and up to and including May 3, 2004 to file
dispositive motions.
DEFENDANT,
SHANER OPERATING CORP,
d/b/a RADISSON HOTEL &
CONFERENCE CENTER
By: gililltnii , ig cg
William J. Anthorgf (c 17865) "
Jackson Lewis LLP
55 Farmington Avenue nite 1200
Hartford, CT 06105
Tel, (860) 522—0404
Fax. (860) 247-1330
E~mail: antl1onyw@jacksonlewiscom

Case 3:03-cv—OO575—l\/IRK Document 12 Filed O2/23/2004 Page 3 of 3
CERTIFICATION OF SERVICE
This is to certify that a copy ofthe foregoing was sent by first class mail, postage
prepaid, on this Q_Oday of February, 2004, to the following:
Bruce A. Chaplin, Esq,
208 Main Street
Barham, CT 06422
W ‘— Odd >¢··
William J , Anthony
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