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

Case 3:03-cv-00630-DJS Document 73 Filed 05/12/2004 Page 1 of 4
UNITED STATES DISTRICT COURT
DISTRICT OF CONNECTICUTT
MARIO RICHARDS, "‘
* CIVIL ACTION NO:
Plaintiff, °"
at
v. "“ 3:03 CV 00630 (DJS)
st
it
COMPUTER SCIENCES CORPORATION, "‘
"‘ MAY 12, 2004
Defendant. *
at
it-
DEFENl`)AN'I"S MOTION ON CONSENT FOR EXTENSION OF DISPOSITIVE
MOTIONS ANI) TRIAL BRIEF DEADLINES
Pursuant to the Federal Rules of Civil Procedure and the Local Rules of
this Court, the Defendant, Computer Sciences Corporation, hereby respectfully moves for
an extension ofthe deadline for filing dispositive motions, and if no dispositive motions
are filed, extension of the deadline for the parties to file their joint trial meinorandum.
Defendant requests that the deadline for dispositive motions be extended to 45 days after
the court rules on currently pending motions and if no dispositive motions are filed, that
the parties tile their joint trial memorandum by 60 days after the court rules on currently
pending motions. In support of this Motion, Defendant states as follows:
1. Plaintiff filed a Motion for Class Certification and Permission to Serve
Notice on September 2, 2003. Defendant filed an Opposition on October 14, 2003 and
Plaintiff tiled his Reply on November l7, 2003. On November 26, 2003 Defendant filed
a Motion for Permission to file a Sur—Replyl

Case 3:03-cv-00630-DJS Document 73 Filed 05/12/2004 Page 2 of 4
2. Defendant also filed on October 14, 2003 a Motion to Strike the Affidavit
of Flaintiff, Mario Richards. Plaintiff filed an Opposition on November 19, 2003 and
Defendant filed a Reply on December 3, 2003.
3. On December 10, 2003 Defendant tiled a second Motion to Strike or
Disregarding Plaintiffs Aftidavits Submitted with his Reply Brief
4. These Motions are currently pending before the Court. Also pending
before the Court are Plaintiffs Motion to Coinpel discovery and Defendants Motion to
Compel discovery.
5. Defendant requests this extension because there are matters raised in the
currently pending motions that would directly impact dispositive motions and the trial
brief.
6. This is the first Motion to extend the deadlines for filing dispositive
motions and/or the trial brief. There were previous motions to extend the deadline for
discovery.
7. Counsel for Defendant has contacted counsel for Plaintiff and he had no
objection to this Motion.
WHEREFORE, Defendant requests that the deadline for dispositive motions be
extended to 45 days after the court rules on currently pending motions and if no
dispositive motions are tiled, that the parties tile their joint trial memorandum by 60 days
after the court rules on currently pending motions.
2

Case 3:03-cv-00630-DJS Document 73 Filed 05/12/2004 Page 3 of 4
DEFENDANT,
CO1\/IPIETER SCIENCES
CORPORATION
By: C Z {
Tasos C. Paindiris (ct 16739)
Wiiliam J. Antliouy (ct 17865)
Jackson Lewis LLP
55 Farmington Avenue, Suite 1200
Hartford, CT 06105
Tel. (860) 522-040-4
Fax, (860) 247-1330
pai1idirt@§acksonlewiseom
Lisa A, Sczhreter (ct 17647)
Jackson Lewis LLP
245 Peachtree Center AV€11U€,N.E.
1900 Marquis One Tower
Atlanta, GA 30303-1226
Tel. (404) 525-8200
Fax, (404) 525-1173
SCi)1“`Bt6i[@}.HCi{SO11i€W1S.COIl1
3

Case 3:03-cv-00630-DJS Document 73 Filed 05/12/2004 Page 4 of 4
CERTIFICATION OF SERVICE
This is to certify that a copy of the foregoing was sent by first class mail,
postage prepaid, on this 12th day of May, 2004, to the following:
Michael J . Meily, Esq.
Bartinik, Giauacoplos, Bartinik, Bartinik & Grater, PC.
100 Fort Hill Rd.
Groton, CT 06340
Iigsos C. Paiadiris