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

Case 3:03-cv-01053-AVC

Document 13

Filed 12/06/2004

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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)

December 2, 2004

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 February 1, 2004 within which to designate its expert witnesses and from January 1, 2005 to March 1, 2005 to complete discovery. This additional time is requested because counsel for the defendant has just recently received plaintiff's responses to defendant's interrogatories and request for production of documents. Upon receipt of this information, the parties have now scheduled depositions but will need additional time to designate expert witnesses and otherwise complete all remaining discovery.

Case 3:03-cv-01053-AVC

Document 13

Filed 12/06/2004

Page 2 of 3

This is the second 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 13

Filed 12/06/2004

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 December, 2004, 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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