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

Case 3:00-cv-00794-CFD

Document 46

Filed 04/21/2004

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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)

APRIL 19, 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, Thursday, June 3, 2004, in which to file the joint trial memorandum in the above captioned matter. This matter was on the court's trial calendar call on April 8, 2004 in which the counsel for the parties reported their trial readiness, availability, interest trial before Magistrate Judge and other issues that may face the court in the trial of this matter. At that time, the Court agreed to extend the filing of the joint trial memorandum until Thursday, June 3, 2004 and instructed the parties to file a motion.

ORAL ARGUMENT IS NOT REQUESTED

Case 3:00-cv-00794-CFD

Document 46

Filed 04/21/2004

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As this motion is filed jointly, plaintiff's counsel 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. 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

Document 46

Filed 04/21/2004

Page 3 of 3

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 19th day of April, 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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