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

Case 3:03-cv-01053-AVC

Document 17

Filed 02/24/2005

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UNITED STATES DISTRICT COURT DISTRICT OF CONNECTICUT

MARK CROFUT, Plaintiff, v. UNITED STATES OF AMERICA, Defendant.

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Civil No. 3:03CV1053 (AVC)

February 23, 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 April 1, 2005 within which to designate its expert witnesses and May 1, 2005 to complete all discovery. This additional time is requested because although the parties have conducted some preliminary discovery, it has became clear during the plaintiff's deposition that he has additional medical records that have to be produced before the defendant can secure and designate expert witnesses, complete depositions of all treating doctors and otherwise complete all remaining discovery. Additionally, a settlement conference is scheduled to commence on March 31, 2005, before PJO Murphy.

Case 3:03-cv-01053-AVC

Document 17

Filed 02/24/2005

Page 2 of 3

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) (203) 579-5575 (facsimile) [email protected]

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Case 3:03-cv-01053-AVC

Document 17

Filed 02/24/2005

Page 3 of 3

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 February, 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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