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

Case 3:03-cv-01053-AVC

Document 11

Filed 10/13/2004

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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)

October 13, 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 December 1, 2004 within which to designate its expert witnesses and from November 1, 2004 to January 1, 2005 to complete discovery. This additional time is requested because counsel for the plaintiff has again advised counsel for the defendant, in numerous telephone conversations, that he has been unable to respond to the Interrogatories and Request for Production of Documents, which were due on June 21, 2004, due to the plaintiff's infirmity. Without that information including medical and treatment records of the plaintiff, the defendant has been unable to depose the plaintiff. The information gathered from the discovery responses as well as the plaintiff's deposition will be needed in order for an expert witness to render an opinion.

Case 3:03-cv-01053-AVC

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Filed 10/13/2004

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This is the second motion to extend this time limitation. Counsel for the plaintiff has indicated that he has no objection to the granting of this motion. Respectfully submitted, KEVIN J. O'CONNOR UNITED STATES ATTORNEY

FOR:

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]

BY:

LISA E. PERKINS ASSISTANT UNITED STATES ATTORNEY FEDERAL BAR NO. CT 23164

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Case 3:03-cv-01053-AVC

Document 11

Filed 10/13/2004

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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 13th day of October, 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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