Free Notice of Appearance - District Court of Connecticut - Connecticut

Case 3:00-cv-00681-RNC

Document 111

Filed 02/02/2004

Page 1 of 3

UNITED STATES DISTRICT COURT DISTRICT OF CONNECTICUT TITUS MOORE Plaintiff VS. MARK A. SANK TROW & SANK, P.C. Defendants : : : : : : : :

CIVIL ACTION NO. 3:03 CV 00801 (CFD)

February 2, 2004

MOTION FOR ENLARGEMENT OF TIME The plaintiff has served upon the defendants, Mark A. Sank and Trow & Sank, P.C. ("Defendants") interrogatories, production requests, and requests for admission, dated August 26, 2003 ("First Discovery Requests"). On or about October 23, 2003, Defendants moved for an enlargement of time (the "Motion") to respond to the First Discovery Requests so that Defendants could devote their efforts to preparing for a settlement conference, which the Court had scheduled before United States Magistrate Judge Thomas Smith on November 14, 2003. The Court (Droney, U.S.D.J.) granted Defendants' Motion on or about November 20, 2003. The Court granted the enlargement up to and including thirty (30) days following the November 14, 2003 Settlement Conference. During the November 14, 2003, Settlement Conference, and after approximately two (2) hours of negotiations, Magistrate Judge Smith agreed to reconvene the settlement conference on Monday, December 15, 2003.

One Goodwin Square 225 Asylum Street Hartford, CT 06103

HALLORAN & SAGE LLP

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

Case 3:00-cv-00681-RNC

Document 111

Filed 02/02/2004

Page 2 of 3

In an effort to make the most productive use of the December 15, 2003, Settlement Conference, the parties agreed, and Magistrate Judge Smith ordered, that Defendants would compile and disclose to the plaintiff certain information, which information would be helpful in resolving the instant litigation. Defendants compiled the requested information and disclosed said information in affidavit form to the plaintiff on December 11, 2003. Defendants expended a considerable amount of time, resources, and effort in compiling and disclosing the information in advance of the December 15, 2003 Settlement Conference. The December 15, 2003, Settlement Conference was postponed due to inclement weather. On December 23, 2003, the court granted an additional extension through January 31, 2004. Because Defendants expended a considerable amount of time, resources, and effort in compiling and disclosing the aforesaid information in advance of and for the December 15, 2003 Settlement Conference, Defendants request an opportunity to attend a settlement conference in an effort to resolve this matter prior to devoting additional time, resources, and effort in responding to the First Discovery Requests. Accordingly, Defendants respectfully request this Court to enlarge the time to serve responses to the First Discovery Requests, up to and including thirty days from the reconvened settlement conference, which has currently not be rescheduled. Defendants request this extra time so that it can continue to devote its efforts toward settling this matter.
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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

Case 3:00-cv-00681-RNC

Document 111

Filed 02/02/2004

Page 3 of 3

This is the fourth request for an enlargement of time related to discovery, which Defendants have made in this case. Defendants have previously sought plaintiff's position regarding their third motion for enlargement of time. The plaintiff did not consent. Accordingly, Defendants believe that the plaintiff does not consent to this Motion. DEFENDANTS, MARK A. SANK TROW & SANK, P.C.

BY:

__________________________ Patrick M. Birney of HALLORAN & SAGE LLP Fed. Bar No. ct19875 One Goodwin Square 225 Asylum Street Hartford, CT 06103 Tel: (860) 522-6103

CERTIFICATION This is to certify that on this 2nd day of February, 2004, the foregoing was either mailed, postpaid, or hand-delivered to: Atty. Joanne S. Faulkner 123 Avon Street New Haven CT 06511-2422

_________________________ Patrick M. Birney
510581.1(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