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

Case 3:01-cv-02205-PCD

Document 54

Filed 03/12/2004

Page 1 of 2

UNITED STATES DISTRICT COURT DISTRICT OF CONNECTICUT

LYNN BALDONI, Plaintiff, VS. THE CITY OF MIDDLETOWN, J. EDWARD BRYMER and DOMENIQUE S. THORNTON Defendants.

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CIVIL ACTION NO. 3:01 CV2205 (PCD)

MARCH 12, 2004

MOTION TO EXTEND DEADLINE TO COMPLY WITH COURT'S AMENDED TRIAL PREPARATION ORDER Pursuant to D.Conn. L. Civ. R. 7(b), the defendants respectfully request a seven (7) day extension of time - - up to and until March 22, 2004 - - in order to comply with Section C of the Court's Amended Trail Preparation Order. This is the first request pertaining to this deadline. The reason for this request is that defense counsel has been diligently compiling the various materials, including proposed jury charges and interrogatories, and requires an additional week to adequately comply. Trial is not scheduled to begin in this matter until April 12, 2004, and thus the plaintiff will not be prejudiced by this extension. Section C compliance will be made well in advance of trial. The undersigned counsel has contacted plaintiff's attorney, Erin O'Neil, and she does not object to this Motion. Attorney O'Neil also indicated that she will be filing a similar motion shortly.

One Goodwin Square 225 Asylum Street Hartford, CT 06103

HALLORAN & SAGE LLP

Phone (860) 522-6103 Fax (860) 548-0006 Juris No. 26105

Case 3:01-cv-02205-PCD

Document 54

Filed 03/12/2004

Page 2 of 2

THE DEFENDANTS: CITY OF MIDDLETOWN, J. EDWARD BRYMER, AND DOMENIQUE S. THORNTON By James M. Sconzo Fed. Bar # ct 04571 and Jonathan C. Sterling Fed. Bar # ct24576 HALLORAN & SAGE LLP One Goodwin Square 225 Asylum Street Hartford, CT 06103 (860) 522-6103 CERTIFICATION This is to certify that on this 12th day of March, 2004, I hereby mailed a copy of the foregoing to: Attorney Erin I. O'Neil Brewer & O'Neil 818 Farmington Avenue West Hartford, CT 06119 Trina Solecki, Esq. City Attorney P.O. Box 1300 Middletown, CT 06457 Jonathan C. Sterling
526381.1(HSFP)

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One Goodwin Square 225 Asylum Street Hartford, CT 06103

HALLORAN & SAGE LLP

Phone (860) 522-6103 Fax (860) 548-0006 Juris No. 26105