Free Motion to Continue - District Court of Connecticut - Connecticut

Case 3:00-cv-00311-CFD

Document 130

Filed 03/04/2004

Page 1 of 3

UNITED STATES DISTRICT COURT for the DISTRICT OF CONNECTICUT

: JOHN E. COX, EXECUTIVE DIRECTOR : NEW HAVEN COMMISSION ON : EQUAL OPPORTUNITIES : : Plaintiff : : v. : : EDWARD L. BLAND in his official and : Individual capacities AND NEW HAVEN : HOUSING AUTHORITY : : Defendants and Third Party Plaintiffs, : : v. : : BEACON/CORCORAN, JENNISON, LP, : STAMFORD WRECKING AND : ANDREWCUOMO, SECRETARY : FOR THE DEPARTMENT OF HOUSING : AND UBRAN DEVELOPMENT (HUD) : : Third Party Defendants. : :

Civil Action No. 3: 00 CV 311(CFD)

March 4, 2004

JOINT MOTION FOR CONTINUANCE Stamford Wrecking, at the suggestion of counsel for the plaintiff New Haven Commission on Equal Opportunities, and with agreement of counsel for all other parties, except HUD, whose counsel is away this week, hereby requests a continuance of the hearing currently scheduled for Wednesday, March 10, 2004 at 2:00 p.m.

Case 3:00-cv-00311-CFD

Document 130

Filed 03/04/2004

Page 2 of 3

Currently appearing counsel for Plaintiff, Erskine D. McIntosh concurs with the request of apparent, but not yet appearing, new counsel for the plaintiff, Evans Jacobs. Attorney Jacobs has represented that the plaintiff is deliberating on the position it will take in pursuing the pending complaint and in direction to counsel. It appears one possible outcome may result in the withdrawal of its complaint. Attorney Jacobs indicates that a continuance of thirty (30) days will permit the plaintiff to determine the course it will take and to communicate that decision to the Court and to the other parties so that the matter may proceed in an orderly fashion with the least expenditure of time by the Court and the parties. The undersigned counsel has consulted with counsel for all other parties, except counsel for HUD, who is away this week and will not return until Monday, March 8 in agreement the matter should be continued. WHEREFORE, Stamford Wrecking hereby respectfully request that the Court grant this motion. DEFENDANT, STAMFORD WRECKING COMPANY
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BY: David L. Metzger (ct02035) Metzger & Associates 25 Capitol Avenue Hartford, CT 06106 Tel. (860) 549-5026 Fax (860) 549-5224 E-Mail: [email protected]

Case 3:00-cv-00311-CFD

Document 130

Filed 03/04/2004

Page 3 of 3

CERTIFICATION OF SERVICE This is to certify that a copy of this motion for continuance was sent by facsimile and first class mail, postage prepaid, on this the 4 day of March 2004 to the following counsel of record: Erskine D. McIntosh The Law Offices of Erskine D. McIntosh, P.C. 900 Chapel Street, Suite 535 New Haven CT 06510-2893 Christopher Brigham Christopher L. Brigham Updike, Kelly & Spellacy, P.C. th 265 Church Street, 10 Floor New Haven CT 06510 James J. Perito Susman, Duffy & Segaloff 55 Whtney Avenue New Haven CT 06510 Janet S. Lundberg, Esq. Kokidas & Bluestein, LLP 141 Tremont Street Boston, MA 02111 Christine L. Sciarrino, Office of the U. S. Attorney 157 Church Street New Haven CT 06510
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David L. Metzger