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

Case 3:00-cv-00794-CFD

Document 49

Filed 05/12/2004

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UNITED STATES DISTRICT COURT DISTRICT OF CONNECTICUT

KENNETH A. STACEY v. CITY OF BRISTOL, ET AL

: : : : :

NO.: 3:00CV794 (CFD) (WIG)

MAY 11, 2004

JOINT MOTION FOR EXTENSION OF TIME TO COMPLETE JOINT TRIAL MEMORANDUM The defendants, City of Bristol, Officer David Carella, Detective Kevin Mellon, Detective Suchinski, Detective R. St. George, Detective Sgt. R. Mullaney, Detective Sgt. Barton, Officer F. Sanders, Officer David Thompson, Officer Davis, Officer F. Daugeneck, John Doe and Jane Doe, hereby move for an extension of time up to and including, Friday, June 18, 2004, in which to file the joint trial memorandum in the above captioned matter. In support of this motion, the defendants offer as follows: 1. The Court has already extended the filing of the joint trial memorandum until June 3, 2004; 2. The parties have been discussing settlement and reached a tentative agreement which requires the consent of the Legislative Body of the City of Bristol; 3. 4. The next meeting of that Legislative Body is not until June 8, 2004; The expenditure of time and fees associated with the preparation of the

Case 3:00-cv-00794-CFD

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joint trial memorandum would adversely impact the ability to obtain consent to settle; 5. Therefore, a two-week extension of time would be appropriate under the circumstances. The undersigned counsel has contacted counsel for the plaintiff, Attorney James Sullivan, and Attorney Sullivan has no objection to the granting of this motion. WHEREFORE, the defendants pray that their motion for an extension of time with which to file their joint trial memorandum up to and including June 18, 2004, be granted. DEFENDANTS, CITY OF BRISTOL, OFFICER DAVID CARELLA, DETECTIVE KEVIN MELLON, DETECTIVE SUCHINSKI, DETECTIVE R. ST. GEORGE, DETECTIVE SGT. R. MULLANEY, DETECTIVE SGT. P. BARTON, OFFICER F. SANDERS, OFFICER DAVID THOMPSON, OFFICER DAVIS, OFFICER F. DAUGENECK, JOHN DOE AND JANE DOE

By/s/John J. Radshaw, III John J. Radshaw, III, ct19882 Howd & Ludorf 65 Wethersfield Avenue Hartford, CT 06114 (860) 249-1361 (860) 249-7665 (fax) e-mail: [email protected]

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Case 3:00-cv-00794-CFD

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Filed 05/12/2004

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CERTIFICATION This is to certify that a copy of the foregoing has been sent, handling charges prepaid, via U. S. Mail to the following counsel of record this 11th day of May, 2004.

James Sullivan, Esquire Howard, Kohn, Sprague & FitzGerald P.O. Box 261798 237 Buckingham Street Hartford, CT 06126-1798

/s/John J. Radshaw, III John J. Radshaw, III

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