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

Case 3:03-cv-00301-DJS

Document 23

Filed 11/19/2004

Page 1 of 2

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

NOVEMBER 18, 2004

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 sixty days for the completion of discovery to be completed, until January 17, 2005. The parties are in the midst of scheduling the deposition of the defendants, however in discussing available dates it became apparent that a short period of time beyond the existing December 1, 2004 deadline will be required. This is the first 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.

Case 3:03-cv-00301-DJS

Document 23

Filed 11/19/2004

Page 2 of 2

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

CERTIFICATION OF SERVICE This is to certify that a copy of the foregoing was mailed this 18thday of November, 2004, 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