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

I se 3:03-cv-007075PCD Document 26 Filed O4/05/2004 Page 1 of 2
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I UNITED STATES DISTRICT COUQRTIT ; _- I. I ,
I FOR THE lu. tl lm >.- EQ F .jY.j¤;,»
I DISTRICT OF CONNECTICUT -
I DEBORAH E. GRAY : CIVIL ACTION NO.
I Plaintiff : 3:03-CV-707(PCD)
I v.
coNsUMERs MTERSTATE 2 I
I CORPORATION and KENNETH 2
I FISCHBURG, Individually And In His : I
I Official Capacity : I
I Defendants : APRIL 1, 2004 Y
I MOTION FOR EXTENSION OF TIME
The Plaintiff hereby requests an extension of time of thirty (30) days to May 30, 2004
to complete depositions of fact witnesses for the following reasons: At the first mediation held I
on March 25, 2004 before David E. Shancupp, PJO, it was his suggestion to have the
deposition of the Plaintiff go forward and schedule another mediation session thereafter.
Plaintiff s deposition has now been completed and another mediation has been scheduled
before PJ O Shancupp on April 19, 2004. Rather than spend resources on discovery that could
be used for settlement, it was agreed that we would hold up on discovery until after the
mediation session. If the case did not settle, we would then resume discovery. This is I
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Plaintiffs first request for an extension of time in which to complete depositions of fact I
witnesses. Undersigned coimsel for the Plaintiff represents that he contacted Brenda A. Eckert, I
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Moruz, COOPER Br MCCANN, LLP • ATTormEvs AT LAW I
100 ALLYN STREET • HARTFORD, CT 06103 · (S60) 276-0200 • FAX (860) 278-2212 • Jums N0. 418370

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1se 3:03-cv-007879PCD Document 26 Filed O4/05?OO4 Page 2 of 2 I
Esq., counsel for the defendants, who stated she has no objection to this extension. 5
Plaintiff also certiiies that this matter has not been assigned for trial.
PLAINTIFF `
B / p l
1 J sep A. Moniz (ct04316) ’
oniz, Cooper & McCann, LLP
100 Allyn Street
Hartford, CT 06103
Tel. (860) 278-0200 |
His Attorneys
CERTIFICATION
THIS IS TO CERTIF Y that a copy of the foregoing was mailed, postage prepaid, this
date to:
Brenda A. Eckert, Esq. I
Gregg P. Goumas, Esq.
Shipman & Goodwin LLP
One American Row
Hartford, CT 06103 A. I
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I / Joseph A. Moniz
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MONIZ, COOPr:R 8: MCCANN, LLP · Arromaezvs AT n.Aw l
100 ALLYN Srmazr • HARTFORD, CT 06103 • (860) 278-0200 • F1¤·xt8G0) 278-22 1 2 • Jums No. 418370
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