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

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Case 3:03-cv-01050-DJS Document 17 Filed O2/13/2004 Page 1 of 3 i
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UNITED STATES DISTRICT COURT
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MARY SAROJAK, i CIVIL ACTION NO.
PLAINTIFF, i 3 :03CV1050 (DJ S)
v. I 9
THE METALLICS GROUP D/B/A , E
METALLICS, INC. and F. MICHAEL { i
MOLA, :
DEFENDANTS.
{ FEBRUARY 12, 2004
DEFENDAN'I`S’ MOTION TO MOD FY SCHEDULING ORDER
The Defendants, Metallics, Inc. and F. Michael Mola, hereby request a modification of
the scheduling order entered by this Court on September 24, 2003. In support of this request the
Defendants represents the following:
I l. The Parties have yet to close the pleadings. The Defendants filed a Motion to
Dismiss that has yet to be ruled upon by this Court.
2. The Plaintiff; Mary Saroj ak, recently responded to the Defendants’ First Set of
Intenogatories and Requests for Production. There are a number of objections
pending which require resolution prior to further discovery
ORAL ARGUMENT NOT REQUESTED
TESTIMONY NOT REQUIRED

. Case 3:03-cv-01665)-DJS Document 17 Filed 02615/2004 Page 2 of 3 {
3. The parties have agreed to mediation in hopes of resolving this matter. Mediation is
scheduled for April 7, 2004. As such, they have refrained from propotmding any
further written discovery or conducting any depositions.
4. The undersigned counsel has contacted the Plaintiff s counsel to obtain his position
on this request for modification and he consents to the requested modification of three
(3) months.
E

WHEREFORE, the Defendants respectfully request that the Court modify the present I
‘ scheduling order to extend the deadlines by three (3) months.
THE DEFENDANTS, I
METALLICS, INC. AND F. MICHAEL MOLA
By:
Mic ael R. Brandt (ctl 8308
Ryan & Ryan, LLC
105 Court Street, Suite 303
New Haven, CT 06511
(203) 752-9794
Their Attorneys
2 i

,. Case 3:03-cv—O1953-DJS Document 17 Filed O2%1%2004 Page 3 of 3
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l CERTIFICATION
The undersigned hereby certified that the foregoing Defendants’ Motion to Modify
Scheduling Order was mailed, first class, postage prepaid, this 12m day of February 2004 to all
counsel and pro se parties of record as listed below:
For Plaintiff Mgy Saroj ak
Robert Fortgang Associates
Greystone Court
573 Hopmeadow Street
Simsbury, Connecticut 06070 Z E §
Mic ael R. Brandt
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