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

Case 3:03-cv-00301-DJS

Document 26

Filed 01/14/2005

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

JANUARY 13, 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 forty-five days for the completion of discovery to be completed, until February 28, 2005. The parties have partially completed the deposition of the plaintiff and had scheduled a second date as well as the deposition of Defendant Smith for January 10, 2005. On January 9, 2005 the undersigned fell unexpectedly and seriously ill and was unable to return to work until Thursday January 13, 2005, making it necessary that a short extension beyond the existing January 17, 2005 deadline be requested. This is the second request to enlarge the scheduling order by the plaintiff. The

Case 3:03-cv-00301-DJS

Document 26

Filed 01/14/2005

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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 26

Filed 01/14/2005

Page 3 of 3

CERTIFICATION OF SERVICE This is to certify that a copy of the foregoing was mailed this 13thday of January, 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