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

Case 3:03-cv-01045-WWE Document 40 Filed 03/17/2005 Page 1 of 3
UNITED STATES DISTRICT COURT
DISTRICT OF CONNECTICUT
WILLIAM LAPUT, ) CIVIL ACTION NO.:
)
Plaintiff ) 3:03CV1045 (WWE)(HBF)
)
v. )
)
LARKIN ENTERPRISES, INC., )
)
Defendant ) March 17, 2004
JOINT MOTION FOR EXTENSION OF DISCOVERY SCHEDULE
AND OF SETTLEMENT CONFERENCE
Plaintiff, William Laput, and Defendant, Larkin Enterprises, Inc., by and through
the undersigned counsel, hereby jointly request an extension of time of forty-five (45) days,
up to and including May 2, 2005, to complete discovery in the above matter. The parties .
also request that the settlement conference before the Honorable H. Fitzsimmons, which is
presently scheduled for Friday, April 1, 2005, be rescheduled. In support for this Motion,
the parties state the following:
1. Discovery presently is scheduled to close on March 17, 2005.
2. Due to scheduling difficulties, the parties have not been able to schedule the
depositions of two witnesses, Terri Bell and Joe Alexander, who reside out of state. The
defendant has represented that although both Mr. Bell and Mr. Alexander are not

Case 3:03-cv-01045-WWE Document 40 Filed 03/17/2005 Page 2 of 3
Connecticut residents, are beyond the subpoena power ofthe District Court, and would
normally be deposed. outside of Connecticut, it will produce both for depositions in
Connecticut. . . N (
3. Both partiesf counsel believe that mediation is more likely to be successful,
and settlement more likely to occur, after discovery closes. Thereibre, the parties seek an
adjournment of the scheduled settlement conference.
4. The parties have requested four other extensions ofthe discovery schedule.
WHEREFORE, the patties respectliilly request that this motion be granted. “
. PLAIN TIFF: DEFENDANT; ‘ ( _
WILLIAM LAPUT LARKIN ENTERPRISES, INC.
By _____ _ By a 4/ N t
i · el E. Satti (ct 01311) Bemar E. Jacqu ct l2293)
Satti,P1·ova.tz;s, & McNamara, P.C. Pepe & Hazard I V
His Attorney I Its Attorney
225 State Street, Suite 200 225Asylum Street
New London, CT 06320 . Hartford., CT 06103-4302
Telephone No; (860) 447-8975 Telephone No.: (S60) 522-5175
Fax No.: (860)447-9136 Fax No.: (860) 522-2796
E-mail: m__snu@sgmemnn_axs.g i TT ` l
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Case 3:03-cv-01045-WWE Document 40 Filed 03/17/2005 Page 3 of 3
CERTIFICATION
This is to certify that a copy of the foregoing has been mailed, postage prepaid, this
17*** day of March 2005 to all counsel and parties of record as follows:
Counsel for Plaintiff:
Michael E. Satti
Shawn L. Rutchick
Satti, Provatas, & McNamara, P.C.
225 State Street, Suite 200
New London, CT 06320 ·
Bernard . Ja s
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