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

Case 3:03-cv-00301-DJS

Document 28

Filed 04/15/2005

Page 1 of 3

UNITED STATES DISTRICT COURT DISTRICT OF CONNECTICUT : : : VS. : : POLICE CHIEF EDWARD FLAHERTY, : ET AL : Defendants : VICTOR PEREIRA Plaintiff CIVIL NO. 3:03 CV0301 (DJS)

APRIL 11, 2005

MOTION TO ENLARGE SCHEDULING ORDER The plaintiff, Victor Pereira, pursuant to Rule 6(b) of the Federal Rules of Civil Procedure, hereby respectfully requests, an enlargement of the scheduling order in the above captioned matter as follows. The plaintiff seeks an enlargement of one hundred and twenty days for the completion of discovery, filing of dispositive motions and filing of the joint trial memorandum to be completed, until August 9, 2005. The original deadlines for these events were February 25, 2005, March 21, 2005 and April 21, 2005, respectively. Plaintiff's counsel has filed this motion in light of his Motion for Withdrawal of Appearance which is being filed concurrently with this motion. Plaintiff's counsel makes this request so as not to seriously prejudice either the Plaintiff himself or opposing counsel during the pendency of the Motion to Withdraw.

Case 3:03-cv-00301-DJS

Document 28

Filed 04/15/2005

Page 2 of 3

This is the third request to enlarge the scheduling order by the plaintiff. The undersigned has contacted counsel for the defendants, Attorney Michele Holmes, who has indicated that she has no objection to the granting of this motion. WHEREFORE, the plaintiff requests that the foregoing request for an enlargement of the scheduling order be granted. THE PLAINTIFF, VICTOR PEREIRA By__________________________ Christopher G. Santarsiero 100 Grand Street Suite 2C Waterbury, CT 06702 (203) 756-5640 CT#13606

Case 3:03-cv-00301-DJS

Document 28

Filed 04/15/2005

Page 3 of 3

CERTIFICATION OF SERVICE This is to certify that a copy of the foregoing was mailed this 12thday of April, 2005, via first class mail, postage prepaid, to the following counsel of record: Attorney Michelle Holmes Sack, Spector & Karsten 836 Farmington Ave. West Hartford, CT 06119 __________________________ Christopher G. Santarsiero