Free Motion to Continue - District Court of Connecticut - Connecticut

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,9, IN UNITED STATES DISTRICT COURT I
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fl §~ _ DISTRICT OF CONNECTICUT
as . §
E THOMAS SANDERS, : ,
5, Plaintiff : DOCKET NO.
EL Xi : 3:00CV740(CF D)
=g \ VS. :
§ § PHILIP L.aFLEUR, GERALD HINES,
g 5 MICHAEL GLOVER AND JOHN :
LI c ARMSTRONG, :
g g Defendants. : FEBRUARY 22, 2004
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LQ j PLAlNTlFF'S MOTION FOR CONTINl,!&GE OF PRE-TRIAL CONFERENCE _
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Q The plaintiff, THOMAS SANDERS, through his undersigned attomey,
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3 2 respectfully moves this Court to reschedule the Pre-Trial Conference that is scheduled
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H g for February 25, 2004 at 2:00 p.m.
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E 0; In support of this Motion, plaintiff represents as follows:
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Q. fg 1. Jury selection is scheduled in this matter for March 17, 2004.
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5 S 2. The Court had previously scheduled a pre-trial conference for February
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Q E 25, 2004 at 2:00 p.m.
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2 E 3. At one point, based on a request by counsel for defendant LaFleur, the
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Q g Courtehedylreswcheduled the pre—trial to February 17*** at 4:00 p.m.
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I . Feb--·ll·ii.C££&43:l00{tfJi/iid)0740-CFD Document 81 Filed 02/24/2004 Page,2 |q3fg3 p _ gl l
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4. At that time, the plaintiff objected tothe rescheduling because his counsel
was picking a jury in a state court criminal case and the evidence was scheduled to j
start on February 17*. _
5. Based on plaintiffs counsels unavailability, the conference was re-set for
the original date and time, i.e. February 25, 2004 at 2:00 p.m. N
6. At that time, counsel anticipated that her state court trial, in the matter of _
State of Connecticut vs. Eggie Rodriguez, Docket Nos. CR 02—4039 and CR 02-4994,
would be concluded by February 23, 2004. That case is being tried by the Hon. Robert I
J. Deviin, Jr.
7. However, the start of evidence in the Rodri uez trial was delayed because l
of a request for additionai laboratory tests made bythe State of Connecticut during jury
selection. .
8. , Evidence is now scheduled to begin on February 24"‘. The Court and the E
parties anticipate that the Rodriguez trial will take four or five days and should end by
· March 2, 2004.
9. Counsel for the plaintiff respectfully requests that this pre—trial conference
be rescheduled immediately after the conclusion of her state court criminal trial, i.e.
after March 2, 2004. T
10. Counsel for the plaintiff has contacted the attorneys for the defendants
who consent to the requested rescheduling.
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V c feb·2tsa£&Ué;ddJt9l5Jt1l0740-CFD Document 81 Filed 02/24/2004 PageO3l<1>ti0 p. 4 I
I 11. There is good cause for granting this motion. J
£ THE PLAINTIFF, THOMAS SANDERS J
L BY:
l DIANE POLAN
Federal Bar No. ctO0223
129 Church Street, Suite 802
New Haven, CT 06510
Telephone: 203-865-5000
Facsimilez 203-865—2‘i 77
His Attorney
CERTIFIQATION
This is to certify that a copy of the foregoing has been sent via first class mail, I
postage prepaid, this 23d day of February, 2004, to the following parties and counsel of
record: 1
Terrence O’NeiIl, Esquire
Assistant Attorney General 2
110 Sherman Street I
Hartford, CT 06106 N
Stephen McE|eney, Esquire
363 Main Street-
Hartford, CT 06105
· _ B l DIANE POLAN —
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