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

Case 3:03-cv-01045-WWE

Document 28

Filed 10/08/2004

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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)(HBF)

OCTOBER 7, 2004

MOTION FOR EXTENSION OF TIME

The Plaintiff, William Laput, ("Plaintiff Laput"), pursuant to Local Rule of Civil Procedure 7(b) hereby requests an extension of time up to and including January 31, 2005, to complete discovery in the above matter. In support hereof and as good cause for such request Plaintiff, Laput, represents as follows: 1. On September 13, 2004 Plaintiff's counsel, Michael Satti, underwent a spinal fusion and removal of a cervical disc and has been prohibited from driving for one (1) month and will be somewhat restricted at least until mid November, 2004. 2. The Plaintiff and Defendant have agreed to postpone the October 29, 2004 Mediation before Magistrate Fitzsimmons and have previously jointly filed a Motion for Rescheduling of Settlement Conference in order to complete the depositions of two out of state witnesses employed by the Defendant. ORAL ARGUMENT NOT REQUESTED 3. On October 7, 2004, the office of the Plaintiff's counsel contacted Attorney Jacques, counsel for Defendant Larkin, who stated that he consents to the requested extension of time in light of the aforementioned surgery and post surgery recuperation.

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Case 3:03-cv-01045-WWE

Document 28

Filed 10/08/2004

Page 2 of 2

4. Plaintiff's and Defendant's have requested two other extensions of the discovery schedule in June and August, 2004. THE PLAINTIFF, WILLIAM LAPUT

By:________________________ Michael E. Satti Satti, Provatas, McNamara, P.C. 225 State Street, Suite 200 New London, CT 06320 (860) 447-8975 Juris No. 418059 -His AttorneysCERTIFICATION The undersigned hereby certifies that the foregoing has been mailed first class postage prepaid, this 7th day of October, 2004 to all counsel and pro se parties of record as listed below: Bernard E. Jacques Pepe & Hazard, LLP 225 Asylum Street Hartford, CT 06103-4302 ______________________ Michael E. Satti

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