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

Case 3:03-cv-00301-DJS

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UNITED STATES DISTRICT COURT DISTRICT OF CONNECTICUT

: : : vs. : : DETECTIVE FRANK KOSHES, DETECTIVE : LAWRENCE SMITH, PATROLMAN TIMOTHY : JACKSON, DETECTIVE MICHAEL GOGGIN, : AND DETECTIVE GARY PECE, : DEFENDANTS.

VICTOR PEREIRA, PLAINTIFF,

CIVIL NO.: 3:03CV0301(AWT)

SEPTEMBER 30, 2004

MOTION TO ENLARGE SCHEDULING ORDER Pursuant to Rule 6(b) of the Federal Rules of Civil Procedure, defendants, Frank Koshes, Lawrence Smith, Timothy Jackson, Michael Goggin and Gary Pece, hereby respectfully request an extension of the scheduling order in the above captioned matter as follows. The defendants seek an enlargement of time of sixty days for the completion of discovery, to be completed, not propounded, until December 1, 2004. The parties have started the deposition

of the plaintiff, and are in the process of scheduling the remainder. The defendants have responded to Interrogatories &

Requests for Production and their depositions will be scheduled to

Case 3:03-cv-00301-DJS

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take place along with the second part of plaintiff's deposition. The undersigned is beginning trial in the case of DeLeon v. City of Waterbury, Et Al., Case No.: 3:01CV00945 (SRU) at Bridgeport Trial

United States District Court on Monday, October 4, 2004. will last 5 to 7 days.

The defendants also seek an enlargement of time of sixty days for the filing of dispositive motions until April 1, 2005. The

undersigned is scheduled to being trial in the Hartford Superior Court in Gonzalez v. Young, Et Al., Case No. CV 00-0800400 S, a consolidated matter that starts jury selection on November 30, 2004 and is expected to take two to three weeks to try. This is the second such request to enlarge the scheduling order requested by these defendants. Pursuant to Rule 9(b)(2), on this date the office of the undersigned called the office of plaintiff's attorney, Christopher Santarsiero, Esquire, who stated that he has no objection to this motion.

Case 3:03-cv-00301-DJS

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DEFENDANTS, DETECTIVE FRANK KOSHES, DETECTIVE LAWRENCE SMITH, PATROLMAN TIMOTHY JACKSON, DETECTIVE MICHAEL GOGGIN, AND DETECTIVE GARY PECE

BY_______________________________ Michelle Holmes Federal Bar Number: ct20014 Sack, Spector & Karsten 836 Farmington Avenue West Hartford, CT 06119 Their Attorney CERTIFICATION This is to certify that a copy of the foregoing has been mailed, postage prepaid, this 30th day of September, 2004, to the following counsel of record:

Christopher Santarsiero, Esquire 100 Grand Street, Suite 2C Waterbury, CT 06702

________________________ Michelle Holmes

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United States District Court Attn: Clerk's Office 450 Main Street Hartford, CT 06103 Honorable Alvin W. Thompson United States District Court 450 Main Street Hartford, CT 06103