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

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UNITED STATES DISTRICT '" 5 p `: OS.
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MARY SARO] AK, I CIVIL
V PLAINTIFF, I 3:03CV1050 (DJS)
THE METALLICS GROUP D/B/A I I
METALLICS, INC. and F. MICHAEL · .
MOLA, I
DEFENDANTS. I
___________________________________ I MAY 4, 2004
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The Plaintiff, Mary Sarojak, and the Defendants, Metallics, Inc. and F. Michael Mola,
hereby jointly request modification of the modified scheduling order entered by this Court on
March 3, 2004 for the reasons set forth below:
l. On May 3, 2004, the parties were notified that the Defendants’ second motion to I
modify scheduling order entered by this Court on March 3, 2004 was denied. As a I
result, the parties have ten days including the weekend, until May 14, 2004, to
complete discovery.
2. As previously submitted to this Court, the parties have entered into mediation with
Attorney Martin Webber in a good faith effort to resolve this matter. A mediation I
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° Case 3:03-cv—0}O£50—DJS Document 22 Filed 05/05/2004 Page 2 of 2
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i session occurred on April 7, 2004; however, the parties agreed that another mediation
i date is necessary to see if an agreement can be reached.
3. Continuing with discovery will have an adverse impact on the parties’ ability to come
to an amicable resolution of this matter. Further, while a notice of deposition has f
been issued for the Plaintiff for May 12, 2004, Plaintiff s counsel is not available on i
that day. {
4. It is for these reasons that the parties are requesting the following modification of the
scheduling order: Discovery, including all discovery relating to depositions and
reports of expert witnesses will be completed by August 25, 2004. Dispositive
motions, if any, will be filed by September 30, 2004. If no dispositive motion is filed,
a joint trial memorandum shall be filed by October 30, 2004. This case shall be trial
ready November, 2004.
5. The parties have mutually agreed upon the modification set forth above and the
undersigned counsel is authorized to represent to the Court that the parties have filed i
this motion jointly.
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