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

Case 3:00-cv-005€4-—.IBA Document 106 Filed 10/$4/2000 Page 1 of 3 I
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UNITED STATES DISTRICT COURT III? II IIi="-PEI rf I I
DISTRICT OF CONNECTICUT
ROLAND COCKFIELD, : CIVIL ACTION NO.
Plaintifg 3:00CV564 (JBA) I
VS. : I
UNITED TECHNOLOGIES CORP.,
PRATT & WHITNEY DIVISION, : I
Defendant. : OCTOBER 23, 2003
DEFENDANT’S MOTION TO MODIFY SCHEDULING ORDER
The Defendant, United Technologies Corporation ("UTC") respectfully requests a
modification of the court’s scheduling order. Specifically, for good cause and the reasons
discussed below, UTC requests that the deadline for filing a pretrial memorandum be extended l2
days to November 15, 2003, and that a trial date be postponed approximately one month (until
after January 7, 2004). Defendant’s Counsel has spoken with Plaintiffs Counsel, Charles Parks,
Jr., who has indicated that he has no objection to such modifications to the scheduling order. I
As this court is aware, the Court issued its decision denying Defendant’s Motion for i
Summary Judgment on October 7, 2003. Since that time, a settlement conference has been
Scheduled with Magistrate Judge Margolis for October 27, 2003. Moreover, during the last two
weeks, counsel for the parties have conferred several times and the Plaintif`f’s counsel also agreed
to supplement his discovery responses. In addition, counsel have also discussed the benefits about
engaging in settlement discussions without the significant cost of preparing a pretrial
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Case 3:00-cv-005€dEQBA Document 106 Filed 10/?d?003 Page 2 of 3 I
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memorandum. Because ofthe upcoming settlement conference and because of the need to receive
supplemental discovery responses, the Defendant requests a small modification of the court’s
scheduling order.
As for the trial date, UTC requests a one-month postponement due to the expected birth of
its counsel’s (Daniel A. Schwartz) second child. Presently, Attorney Schwartz’s wife is expected i
to give birth on November 19, 2003 and thus, he is expected to be out of the office for a minimum {
of two weeks. The time may be significantly longer because ofthe particular medical
circumstances of the pregnancy that counsel would be willing to discuss with the court further if
necessary. In addition, as noted above, UTC is still awaiting supplemental discovery responses by
the Plaintiff and may need the additional time to conduct brief and limited discovery on those
supplemental responses. For these reasons, UTC requests that a trial date be postponed by one
month and scheduled for no earlier than January 7, 2004.
For all of the foregoing reasons, UTC requests that this court modify the scheduling order
to change the deadline to filing a pretrial memorandum until November 15, 2003. In addition,
UTC requests that a trial be scheduled for no earlier than January 7, 2003.
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Case 3:00-cv-005QZl-QIBA Document 106 Filed 10/GZIFOOS Page 3 of 3
DEFENDANT, I
UNITED TECHNOLOGIES CORP.,
PRATT & WHITNEY DIVISION I
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By DOJ ? M.-/’
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Albert Zakarian ( t#042` l) Q
Daniel A. Schwartz (ct#l5823) ,______n_
Day, Berry & Howard
CityPlace I
Hartford, Connecticut 06103-3499
(860) 275-0100
fax: (860) 275-0343
E-Mail: [email protected]
Its Attorneys
CERTIFICATION
THIS IS TO CERTIFY that a copy of the foregoing was sent via electronic mail and mailed
this date, via iirst class mail, postage prepaid to: Charles G. Parks, Jr., Esq., Parks & Associates,
160 Forest Street, Stamford, Connecticut . I
2 I '/ ‘I‘ Q) I
Daniel A. Schwartz
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