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

Case 3:03-cv-01045-WWE

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Filed 01/28/2005

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UNITED STATES DISTRICT COURT DISTRICT OF CONNECTICUT WILLIAM LAPUT Plaintiff, v. LARKIN ENTERPRISES INC. Defendant. : : : : : : : : :

CIVIL ACTION NO. 3:03CV1045(WWE)

JANUARY 27, 2005

MOTION FOR EXTENSION OF DISCOVERY SCHEDULE AND OF SETTLEMENT CONFERENCE The Plaintiff, William Laput, ("Plaintiff Laput"), pursuant to Local Rule of Civil Procedure 7(b) hereby requests an extension of time of forty-five (45) days from January 31, 2005 up to and including March 17, 2005, to complete discovery in the above matter. Plaintiff also requests that the settlement conference currently scheduled for February 14, 2005 before Magistrate Fitzsimmons be rescheduled. In support hereof and as good cause for such request Plaintiff Laput, represents as follows: 1. On November 18, 2004, correspondence was sent to Attorney Jacques' office, Counsel for Defendant, Larkin Enterprises requesting dates that he and two witnesses, Terri Bell and Joe Alexander, were available for depositions in December, 2004. NO ORAL ARGUMENT REQUESTED TESTIMONY NOT REQUIRED

Case 3:03-cv-01045-WWE

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2. After no response was received from Counsel for the Defendant, follow up correspondence was sent to Attorney Jacques' office on November 23 requesting the dates. Shortly after that correspondence was sent, we received a response from Attorney Jacques' paralegal stating that their client had been contacted and that she had forwarded our correspondence onto Attorney Jacques, but she had no dates as of yet. 3. Again, after no response, correspondence was sent to Attorney Jacques stating that considering the amount of time that has passed, the Plaintiff was now requesting dates that he and the witnesses were available for deposition in the months of December, 2004 and January, 2005. 4. On January 5, 2005, correspondence was sent to Attorney Jacques' office notifying them that due to the lack of response on their behalf, the undersigned would be requesting that a status conference be held. 5. Both of the witnesses, Terri Bell and Joe Alexander reside out of state and the Defendant has agreed previously to produce them in Connecticut. 6. Magistrate Fitzsimmons has scheduled this matter for a settlement conference on February 14, 2005. Plaintiff Laput requests that this conference be rescheduled as it is necessary to have completed depositions of these witnesses prior to the settlement conference. 2

Case 3:03-cv-01045-WWE

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Filed 01/28/2005

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7. The Defendant's counsel, Bernard Jacques, has been contacted and he consents to the requested extension of time.

WHEREFORE, the Plaintiff Laput respectfully requests an extension of time up to and including March 17, 2005, to complete discovery and requests that the settlement conference be 3

Case 3:03-cv-01045-WWE

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rescheduled to a mutually convenient time. THE PLAINTIFF, WILLIAM LAPUT

By: _______________________ Michael E. Satti Federal Bar No. ct01311 Satti, Provatas, McNamara, P.C. 225 State Street, Suite 200 New London, CT 06320 (860) 447-8975 His Attorneys

CERTIFICATION This is to certify that on this 27th day of January, 2005, the foregoing was sent First Class Mail, postage prepaid to the following attorneys of record: Bernard E. Jacques Pepe & Hazard LLP 4

Case 3:03-cv-01045-WWE

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225 Asylum Street Hartford, CT 06103-4302 _______________________ Michael E. Satti

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