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

Case 3:03-cv—OO712—WWE Document 71 Filed 08/O2/2004 Page 1 of 3
UNITED STATES DISTRICT COURT
DISTRICT OF CONNECTICUT
GERTRUDE BAYONNE, :
Plaintiff,
v. Docket No. 3:03 CV 0712 (WWE)
PITNEY BOWES INC.,
Defendant. July 29, 2004 A
UNOPPOSED MOTION FOR MODIFICATION OF SCHEDULING ORDER .
Pursuant to Local Rule 9(b), Defendant Pitney Bowes Inc. moves to modify the
scheduling order applicable to this matter. The requested modification seeks to extend by
ninety days the discovery and dispositive motion deadlines. In support of this request,
Defendant avers as follows:
l. Plaintiff consents to the proposed modification;
2. This is Defendant's second request to modify the scheduling order. The first
request sought only to clarify an oversight created when Plaintiff sought to extend the
discovery deadline but failed to request an extension of the dispositive motion deadline. As a
result, the scheduling order permitted the deadline for dispositive motions to expire prior to A
the close of discovery;
3. The present request to modify the scheduling order is necessary to allow the
parties time to complete discovery and prepare for the filing of dispositive motions in a
orderly and efficient manner. In addition, the undersigned attorney just recently filed an
appearance in this matter on July 26, 2004 and is presently in the process of obtaining and
reviewing the file on this matter. Additional time is needed in order to allow Defendant's new
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Case 3:03-cv—OO712—WWE Document 71 Filed 08/O2/2004 Page 2 of 3
counsel time review all pleadings and discovery materials filed and exchanged to date, a task
which will be very difficult to complete prior to September 1, 2004, the date discovery is
presently set to close. Further, the additional time requested to complete discovery will ease
the scheduling constraints presently surrounding the depositions that need to be completed in
this matter before the close of discovery.
WHEREFORE, Defendant Pitney Bowes Inc. respectfully requests that the Court
enter an order modifying the Scheduling Order in this action as follows:
(1) December 1, 2004: Discovery cutoff.
(2) January 15, 2005: Dispositive motion deadline.
THE DEFENDANT
PITNEY · C.
BY EDW ’ " A GELL LLP
ITS AT O is .
By / I
John . Stretton
Fed Bar N0. 19902
Ed ards & Angell LLP
301 Tresser Boulevard
Stamford, CT 06901
Telephone: (203) 353-6844
Fax: (800) 232-0862
E-Mail: j [email protected]
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Case 3:03-cv—OO712—WWE Document 71 Filed 08/O2/2004 Page 3 of 3
CERTIFICATE OF SERVICE
This is to certify that a copy of the foregoing UNOPPOSED MOTION FOR
MODIFICATION OF SCHEDULING ORDER has been sent via first class mail, postage
prepaid to:
Mark P. Carey
Carey & Associates, P.C.
71 Old Post Road, Suite One
Southport, CT 06890
Theodore J. Tucci
Robinson & Cole
280 Trumbull Street
Hartford, CT 06103
Nicole A. Diller
Morgan Lewis & Bockius
One Market
Spear Street Tower
San Francisco, CA 94105
jtlo
; .
this~3__ day of July, 2004. ~~’
J ‘ G. Stretton
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