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

Case 3:02-cv-02200-CFD

Document 60

Filed 09/03/2004

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IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF CONNECTICUT CARLOS A. ARREDONDO, in his capacity as Trustee of The 2000 Trust for the Grandchildren of Carlos A. Arredondo and Mari V. Arredondo, General Partner of Arredondo Properties Limited Partnership, Plaintiff, v. CAESAR A. ARREDONDO, individually and in his capacity as Trustee of The 2000 Trust for the Grandchildren of Caesar A. Arredondo and Carolyn Abad Arredondo; THE 2000 TRUST FOR THE GRANDCHILDREN OF CAESAR A. ARREDONDO AND CAROLYN ABAD ARREDONDO, in its capacity as General Partner of Arredondo Properties Limited Partnership; and ARREDONDO & CO., LLC, Defendants. SEPTEMBER 2, 2004 CIVIL ACTION NO.: 3:02 CV 02200 (CFD)

DEFENDANTS' MOTION FOR ENLARGEMENT OF TIME WITHIN WHICH TO FILE A SUMMARY JUDGMENT MOTION Pursuant to Local Rule 9 of the Local Rules of Civil Procedure, the defendants hereby move for a sixty (60) day extension of time within which to file a summary judgment motion. In support of this motion, the Defendants state the following. 1. Under the current Scheduling Order, motions for summary judgment are due on

September 13, 2004. 2. While the parties have completed the exchange of discovery requests and negotiation

of outstanding discovery issues, there are still outstanding materials that each side has agreed to

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produce to the other in follow-up to recent depositions, but the parties still are in the process of compiling and copying those materials, which materials will impact the Defendants' summary judgment motion. Counsel expects that process to be completed in the next few weeks. 3. Due to a death in the family of undersigned counsel and other court commitments, it

would be difficult for undersigned counsel to complete the summary judgment motion prior to the current due date of September 13. 4. From September 16 through October 2, the Defendant, Caesar Arredondo, will be on

a pre-planned vacation and therefore will be unable to consult with undersigned counsel in the preparation of the summary judgment motion. 5. The Defendants do not believe that the sixty (60) day enlargement of time will impact

the trial readiness for this matter nor will it prejudice the Plaintiffs. 6. Undersigned counsel believes that with the requested enlargement of time, the

Defendants' summary judgment can be prepared properly. 7. Despite attempts by electronic and voice mail messages, the Defendants have not

been able to ascertain the Plaintiff's position on this motion. 8. This is the first request for enlargement of time on this issue.

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DEFENDANTS, CAESAR A. ARREDONDO, et al. By Craig A. Raabe (ct 04116) E-mail: [email protected] Edward J. Heath (ct20992) E-mail: [email protected] Robin P. Keller (ct23564) E-mail : [email protected] Robinson & Cole LLP 280 Trumbull Street Hartford, CT 06103 Tel.: (860) 275-8200 Fax: (860) 275-8299

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ORDER The foregoing motion having been presented to the Court, it is hereby ordered GRANTED/DENIED on this day of , 2004. BY THE COURT ________________________________ Judge/Clerk

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CERTIFICATION This is to certify that a copy of the foregoing was sent first class mail, postage prepaid on this 2nd day of September, 2004, to: Robert P. Dolian, Esq. Cummings & Lockwood LLC 107 Elm Street Stamford, Connecticut 06902 Martin J. Elgison, Esq. David J. Stewart, Esq. Dana Marty Haas, Esq. Alston & Bird LLP One Atlantic Center 1201 West Peachtree Street Atlanta, Georgia 30309-3424

Craig A. Raabe

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