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

Case 3:03-cv-01053-AVC

Document 19

Filed 07/15/2005

Page 1 of 2

UNITED STATES DISTRICT COURT DISTRICT OF CONNECTICUT MARK CROFUT, Plaintiff, v. UNITED STATES OF AMERICA, Defendant. : : : : : : : : :

Civil No. 3:03CV1053 (AVC)

July 13, 2005

MOTION TO EXTEND DISCOVERY DEADLINES SET FORTH IN THE SCHEDULING ORDER Pursuant to Local Rule 7(b) of the Local Rules of Procedure for the District of Connecticut, the Defendant, United States of America, hereby respectfully requests a sixty (60) day extension of time to and including September 12, 2005 within which to complete discovery, designate its expert witnesses and file dispositive motions in the above captioned matter. Due to conflicting demands of counsels' litigation schedules, we have been unable to complete depositions of fact and expert witnesses. This is the third request for an extension of time with regard to this deadline. Counsel for the plaintiff concurs in the granting of this motion. Respectfully submitted, KEVIN J. O'CONNOR UNITED STATES ATTORNEY

BRENDA M. GREEN ASSISTANT UNITED STATES ATTORNEY FEDERAL BAR NO. CT19538 UNITED STATES ATTORNEY'S OFFICE 915 LAFAYETTE BOULEVARD, ROOM 309 BRIDGEPORT, CT 06604 (203) 696-3000 (telephone)

Case 3:03-cv-01053-AVC

Document 19

Filed 07/15/2005

Page 2 of 2

(203) 579-5575 (facsimile) [email protected] CERTIFICATION OF SERVICE This is to certify that a copy of the within and foregoing Motion for Extend Discovery Deadlines Set Forth in the Scheduling Order has been mailed on the day of July, 2005, to:

John Pirina, Jr., Esq. Law Offices of Arnaldo J. Sierra 215 Washington Street Hartford, CT 06106 BRENDA M. GREEN ASSISTANT UNITED STATES ATTORNEY

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