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

. #Case 3:00-cv-00973-AHN Document 73 Filed 1 1/08/2004 Page 1 of 3
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1 UNITED STATES DISTRICT COURT 2111111 1.11111 .. 3 13 Q: I] Cl
1 DISTRICT OF CONNECTICUT
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. TIMOTHY HAYES I: CIVIL ACTION N O: 1
Plaintiff : 3:00CV0973(AHN)(HBF) 1
1 v. : I
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COMPASS GROUP USA, INC., : 1
1 d/b/a EUREST DINING SERVICES : 1
1 and CARY ORLANDI : November 5, 2004
1 Defendants : 1
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I PLAIN TIFF’S MOTION FOR ENLARGEMENT OF TIME
1 WITHIN WHICH TO FILE A JOINT TRIAL MEMORANDUM 1
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1 Pursuant to Rule 6 of the Federal Rules of Civil Procedure and Local Rule '/(b) the I
Plaintiff in the above-captioned matter respectfully moves for an extension of time within which
to tile a Joint Trial Memorandum consistent with the Standing Order Regarding Trial
f\/lemoranda Jn Civil Case under the appendix to the local rules. The Plaintiff represents as
follows: i
1) In their joint scheduling order the parties established, and the court ordered,
that the aforesaid Joint Trial Memorandum be filed within thirty (30) days after the Court rules
on any dispositive motions.
2) The Court’s ruling on the Defendants’ Motion for Summary Judgment was
tiled on October 8, 2004 and thus the Joint Trial Memorandum is due November 8, 2004. 1
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Q ( -Case 3:00-cv-00973-AHN Document 73 Filed 11/08/2004 Page 2 of 3 {
I 3) At the scheduling conference on November 2, 2004 the Court set February l8, i
I 2005 as the date for jury selection in the above-captioned matter. {
i 4) The Court also scheduled a settlement conference with Judge Fitzsimmons on
{ January l2, 2005.
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` 5) The parties jointly request a postponement of the deadline for filing the Joint j
Trial Memorandum to January 24, 2005.
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6) Based on a telephone conference, this date, with Attorney Margaret Paget, }
attorney for the Defendants, the parties are in agreement that the deadline for filing the Joint Trial I
Nlemorandum may be extended to January 24, 2005, shortly following the settlement conference I
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l but in sufficient time prior to commencement of trial. |
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Wherefore, the Plaintiff respectfully moves for good cause that the Court extend the l
deadline for filing the Joint Trial Memorandum to January 24, 2005.
‘ PLAINTIFF _ { l
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Stephen Fi 5 cEle ey
Federal Bar No; c 040730
McEleney & Mc rail
363 Main Street
Hartford, CT 061 6
His Attorney l
Telephone No: (860) 249-1400
Facsimile No: (860) 549-5865
E-mail: stephen.g@,mceleneyl.aw.com
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1 ' A *Case 3:00-cv-00973-AHN Document 73 Filed 11/08/2004 Page 3 of 3
( CERTIFICATION I
I I certify that a copy of the foregoing was sent via first class U.S. mail to the following 1
1 counsel of record this 5"‘ day of November, 2004:
1 Christopher A. Kenney {
: Sherin and Lodgen LLP 1
i 100 Summer Street 1
1 Boston, MA 02110
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\ Margaret H. Paget, Esq.
1 Sherin and Lodgen LLP 1
100 Summer Street 1
Boston, MA 02110
I Lawrence Peikes, Esq. 1
1 Wiggin and Dana LLP
1 400 Atlantic Street
Stamford, CT 06901 1
Pred Frangie, Esq. · ·’i`
Robert Fortgang & Associates
.573 Hopmeadow Street
Simsbury, CT 06070
Stephen F.- cEl ney I-
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