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

ase 3:03-cv-00680—lV|FtK Document 29 Filed 03/02/2004 Page 1 of 3
UNITED STATES DISTRICT COURT
DISTRICT OF CONNECTICUT
L.M., by and through her parents and
next friends, C.D. and A.M., :
: CASE NO. 3:03 CV 0680 (MRK)
Plaintiffs, :
v. :
PUTNAM BOARD OF EDUCATION,
CAROL B. ARNOLD, GEORGEANN :
FARRAH and MELISSA ROSE, :
Defendants.
: MARCH 1, 2004
MOTION FOR EXTENSION OF TIME
Defendants, Putnam Board of Education, Carol B. Arnold, Georgeann Farrah and
Melissa Rose Hedlin move for an extension of time with regards to the discovery
schedule. This is the Defendants first motion for an extension of time with respect to
the discovery schedule. This motion is necessary due to the following reasons. First,
there was delay due to needing approval from the insurance company responsible for
litigation costs. The approval needed for deposing the Plaintiffs’ expert and for hiring an
expert for the Defendants was only granted on February 25, 2004 after weeks of
discussions. Second, there were scheduling conflicts, with Attorney Dorsey being out of
state during the second and third weeks of February and Attorney RockweII’s medical
leave of absence since February 3, 2004. As Attorney Rockwell attempts to work from
home, she has been limited in the amount of work that can be accomplished. In
addition, fact witness depositions had been scheduled for the last week of February, but
needed to be rescheduled for Attorney Feinstein into the second week of March.
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ase 3:03-cv-00680—lV|FlK Document 29 Filed 03/02/2004 Page 2 of 3
The first date available, once approval was given, between the parties and the
PIaintiffs' expert witness is March 19, 2004. Plaintiffs have agreed to a psychological
evaluation of the Student by the Defendants’ expert which cannot be scheduled until the
third or fourth week of March.
Defendants request to extend the March 2, 2004 date for the Defendants to
depose the Plaintiffs’ expert witness until March 19, 2004. This is the date both parties
and the expert witness are available to conduct the deposition.
Defendants request to extend the March 15, 2004 date to disclose an expert
witness and the report until April 16, 2004. Plaintiffs have agreed to a psychological
examination of the Student by the Defendants’ expert witness. However, scheduling the
assessment by the Defendants’ expert cannot be accomplished until the third or fourth
week of March. The expert requires another few weeks to write his report.
Defendants request to extend the April 15, 2004 date for the completion of
discovery until May 17, 2004 to accommodate the changes in the discovery schedule.
Opposing counsel states that he has no position with regard to this motion.
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ase 3:03-cv-00680—IV|FtK Document 29 Filed 03/02/2004 Page 3 of 3
PUTNAM BOARD OF EDUCATION,
CAROL B. ARNOLD,
" GEORGEANN AR H a d
MEL , , T TT y , _ ,
By: % T»~~ * I ·` ,
Werick L. Dor ey ct30 "
Jennifer M. Rockwell ct2 573
Siegel, O’Connor, Zangari,
O’DonneII & Beck, P.C.
150 Trumbull Street
Hartford, CT 06103
Phone: (860) 727-8900
E—maiI: [email protected]
E-mail: jrockwel|@siegeIoconnor.com
CERTIFICATE OF SERVICE
I hereby certify that a copy of the Motion for Extension of Time has been sen/ed
upon counsel for the Plaintiffs, L.M., by and through her parents and next friends, CD. ‘
and A.M., Andrew A. Feinstein, Esq., 34 Jerome Ave., Suite 210, Bloomfield, CT 06002
by first class mail, postage prepaid, this Z D ry day of March, 9 ~ v_,..l
. · . -x r /lv"},
, - , *1Jm A£`i '''Q E U
F derick . Dors y
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