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

N · Case 3:OO—cv-OO7¢?§3FD Document 86 Filed O3/1<6/$004 Page 1 of 4 {
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UNITED srrmizs nrsrmcr coumi Faith MAH I b P si; 5 i,
DISTRICT OF CONNECTICUT .
. !!.}l£§”[R_lCl" COURT
ll.-”`.ii!i·GRi] CT
THOMAS SANDERS : CIVIL ACTION NO:
Plaintiff : 3:00CV00740 (CFD)
V. Z
PHILIP LaFLEUR, GERALD HINES,
MICHAEL GLOVER AND JOHN :
ARMSTRONG : MARCH 16, 2003
Defendants :
MOTION FOR CONTINUANCE FOR
PRETRIAL DEADLINES i
1) On March l0, 2004 this court entered a pretrial order establishing the following dates: I
A) The parties to file memorandum on number of peremptory i
challenges, Motions in Limine regarding evidence and Motions to i
Bifurcate trial, with accompanying Memorandum by March 18, 2004 at i
5:00 p.m. l
B) Opposition papers to the foregoing were to be filed by March 23, 2004 at
5:00 p.m.
C) Arguments on pending motions were to be held on March 25, 2004 at 2:00
2) Subsequent to said pretrial order the parties engaged in settlement discussions which,
although not fruitful, have resulted in the court directing a status conference for the purpose of
discussing settlement for March 23, 2004 at ll:00 a.m.
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i 3) Of the three counsel involved for the parties in this action, the undersigned is in the worst
i position to determine the chances of settlement. However, plaintiffs counsel indicated to the
i undersigned this date that she is optimistic in regard to settlement. The undersigned also
assumes the court scheduled a conference for March 23, 2004 on the theory the conference would
be fruitful.
4) Based on a telephone conference this date with Plaintiffs counsel, it is the understanding
of the undersigned that all parties desire to postpone the March 18, 2004 filing date for all y
motions given the settlement conference scheduled for March 23, 2004. Plaintiffs counsel i
represents that Attorney O’Neil is in favor of this motion.
5) The parties respectfully submit it is in the interest of judicial economy to postpone the
dates for filing of the aforesaid motions and memorandum.
6) Counsel for the Plaintiff has suggested a postponement for filing to a date one week from
the settlement conference, i.e., March 30, 2004.
7) The undersigned is agreement with that date. Attorney O’Neil could not be reached for l
comment on the particular date, but based on the conversation with Plaintiffs counsel, Attorney
O’Neil was certainly in favor of a postponement. E
8) Based on the foregoing, the undersigned proposes the following revised dates for pretrial
order by the court: I
A) March 30, 2004 to tile a memorandum on number of peremptory
challenges, Motions in Limine regarding evidence and Motions to
Bifurcate trial, with accompanying Memorandum; [

· Case 3:00-cv-00740-CFD Document 86 Filed 03/16/2004 Page 3 of 4 i
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B) April 6, 2004 to file opposition papers to the foregoing; and
C) Arguments on pending motions on a date and time to be scheduled by the
p court.
WHEREF ORE, defendant, LaF leur, for the foregoing reasons request a continuance of
the aforesaid motions to the dates stated above.
DEFENDANT
PHILIP LaF

K
Bérr ‘
Stephen M •. y
His Attorne
McE1eney &· cGrai1
363 Main S reet
Hartford, CT 06106
Federal Bar No: Ct 04073
Telephone No: (860) 249-1400
1 Facsimile No: (860) 549-5865
E-mail: [email protected] `

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{ CERTIFICATION
l This is to certify that a copy of the foregoing has been sent via first class U.S. mail,
postage prepaid to the following counsel of record this 16* day of March, 2004:
\ Diane Polan, Esq. 1
l 129 Church Street, Suite 802
New Haven, CT 06510 `
Terrence O’ Neill, Esq. __ __
Attorney Margaret Chapple
Assistant Attorney General
110 Shennan Street I
Hartford, CT 06106
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Stephen. Y /
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